Reassessment jurisdiction fails when notices are issued to a deceased assessee rather than applicable legal heirs.

Reassessment notices must be issued to a living assessee or, where applicable, to the legal heirs. Issuing a show-cause notice, order, or reassessment notice in the name of a person who died before proceedings began creates a substantive jurisdictional defect, not a curable procedural irregularity. Such proceedings are null and void and liable to be quashed.

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Issues: Whether reassessment proceedings initiated through a show-cause notice, order and reassessment notice issued in the name of a deceased assessee are valid.

Analysis: A notice for reassessment is the foundational jurisdictional requirement. It must be issued to a living assessee or, where applicable, the legal heirs. Issuance in the name of a person who had died before initiation is a substantive jurisdictional defect and not a curable procedural irregularity.

Conclusion: The show-cause notice, the order and the reassessment notice issued in the deceased assessee's name were null and void and were quashed.

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