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 Please become a Premium member. If you are already a Premium member, login here to access the full content.