In absence of valid notice, AO has no authority to assume jurisdiction U/s. 147 

Late Bharti Harendra Modi by Her Legal Heir Nikhilharendr Modi Vs ITO (Gujarat High Court)

The notice under section 148 of the Act, which is a jurisdictional notice, has been issued to a dead person. Upon receipt of such notice, the legal representative has raised an objection to the validity of such notice and has not complied with the same. The legal representative not having waived the requirement of notice under section 148 of the Act and not having submitted to the jurisdiction of t

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