Jurisdiction Fatal When 148 Notice Is in Name of Deceased Assessee

Lalita Agarwal (Legal Heir of Late Shri Subhash Chandra Agarwal) Vs ACIT (ITAT Mumbai)

In these five appeals, legal heir of Late Subhash Chandra Agarwal challenged reopening notices u/s 148 & consequential assessments framed entirely in the name & PAN of the deceased, despite the department being duly informed of the death on 23.01.2015 along with the death certificate.

Tribunal noted that for all years, notices u/s 148 as well as assessment orders u/s 147/144 were issued exclusively in the name of the deceased &  on his PAN, even though parallel proceedings wer

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