Section 148 Notice to Legal heirs after expiry of limitation period is invalid

Sh. Shambhu Dayal, Ravi Dutt, Gori Shankar Rajesh Rohit L/h Late Sh. Jhabar Mal (ITAT Jaipur)

The undisputed facts are that the assessee, Shri Jhabar Mal Kumawat had expired on 10.10.2015 as noted by the AO in the assessment order. Thereafter, the reasons for reopening the assessment u/s 147 were recorded and after seeking approval from the Competent authority, the notice u/s 148 was issued in the name of deceased assessee on 31.03.2017. Therefore, at the time of issuance of the notice u/s 148, the assessee had already expir

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