Reassessment notice issued to a deceased person is without jurisdiction and the proceedings are liable to be quashed.

Reassessment proceedings initiated under sections 147, 148 and 144 were held invalid because the section 148 notice was issued in the name of a person who had already died. Proceedings begun against a deceased person are without jurisdiction, and the defect goes to the root of the reassessment. As the fact of death was already on record before the appellate authority, the reassessment could not be sustained and was set aside.

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Issues: Whether reassessment proceedings initiated under sections 147, 148 and 144 of the Income-tax Act, 1961 were valid when the notice under section 148 was issued against a person who had already died.

Analysis: The assessee had died before issuance of the notice under section 148, and the fact of death was on record before the appellate authority. Proceedings commenced in the name of a deceased person are without jurisdiction and cannot be sustained. The defect goes to the root of the reassessment proceedings, making them liable to be quashed.

Conclusion: The reassessment proceedings were invalid and were set aside; the appeal succeeded for the assessee.

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