Section 148 notice cannot be issued against deceased Assessee

Rajender Kumar Sehgal Vs ITO (Delhi High Court) When the notice was issued, the assessee was already dead. If the Department intended to proceed under Section 147 of the Act, it could have done so prior to 31st March 2017 by issuing a notice to the LRs of the deceased. Beyond that date it could not have proceeded in the matter even by issuing notice to the LRs of the assessee. If the original assessee had lived and later participated in the proceedings, then, by reason of Section 292BB, she would have been precluded from saying that no notice was factually served upon her. When the notice was ...