Section 148 Reassessment Invalid for Want of Notice to Legal Heir: ITAT Delhi

Amit Singh Vs ITO (ITAT Delhi) Overview– The Tribunal quashed the reassessment proceedings as void ab initio, holding that issuance of notice under Section 148 to a deceased assessee without serving the legal heir vitiates jurisdiction under Section 147 and cannot be cured by subsequent participation. Facts– In this case, notices were issued under Section 148 of the Income Tax Act in the name of the deceased assessee, Mahender Singh. However, no notice under Section 148 was ever issued to the legal heir, Amit Singh, who is the assessee before the Tribunal. The assessee contende...