Section 271(1)(c) Penalty cannot continue after Assessee’s Death

Late Jayant Maneklal Wagle Vs ACIT (ITAT Pune) The appeal before the Pune Bench of the Income Tax Appellate Tribunal concerned penalty proceedings under Section 271(1)(c) of the Income Tax Act, 1961 for Assessment Year 2005-06. The appeal was filed against the order of the National Faceless Appeal Centre (NFAC) dated 03.08.2023. At the outset, the Tribunal considered a preliminary issue regarding the validity of penalty proceedings initiated after the death of the assessee. The assessee, Shri Jayant Maneklal Wagle, had died on 19.11.2007. Despite his demise, subsequent proceedings continued, i...