Reassessment Proceedings cannot be initiated against a dead person

Ela Roy Vs ITO (Calcutta High Court)

Petitioner being the sister of the noticee, in response to notice under Section 148 of the Act has filed the return. Petitioner submits that she being a lay person, due to inadvertence has filed the return on behalf of her brother noticee though she had already informed the department at the same time that the noticee has already expired. Be that as it may, the fact remains that no proceeding can be initiated against a dead person and the assessing offier after having notice and knowledge that the noticee has already

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