Revision proceedings against a deceased assessee are invalid when initiated and completed in the deceased person's name.

Proceedings under section 263 initiated against a deceased assessee are described as a nullity where the death had been intimated during the original assessment and that assessment was completed in the legal heir's name. The notes distinguish this from proceedings validly initiated against a living person, which may continue against legal heirs after notice. On the stated facts, the revisional order was passed in the deceased person's name and is described as invalid and quashed.

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Issues: Whether a revisional order initiating fresh assessment proceedings under section 263 against an assessee who had died before its initiation is legally valid.

Analysis: The death of the assessee had been intimated during the original assessment proceedings, and the assessment under section 143(3) was made in the name of the legal heir. The revisional order, however, was passed in the deceased assessee's name. Proceedings initiated against a dead person are a nullity; this is distinct from proceedings validly commenced against a living person and subsequently continued against legal heirs after notice.

Conclusion: The revisional order under section 263 passed against the deceased assessee was invalid and was quashed, in favour of the assessee.

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