Revisionary proceedings against a deceased assessee are void when no valid continuation against legal heirs is initiated.

Revisionary proceedings initiated against a deceased person are void where no lawful continuation against the legal heirs is shown. On the admitted dates and the death certificate, the show-cause notice and order were issued after the assessee's death, so the section 263 order was a nullity and could not survive. As the revision order itself was invalid in law, the remaining grounds were not examined.

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Issues: Whether the revisionary order passed under section 263 on a person who had already died was valid in law.

Analysis: The assessee had died before the show-cause notice and the impugned order were issued. The legal position applied was that proceedings initiated against a deceased person are void where no valid continuation against legal heirs is shown to have been commenced in the manner recognised by law. In view of the death certificate and the admitted dates, the revisional proceedings were held to have been taken against a dead person and could not survive. Since the revision order itself was found to be a nullity, the remaining grounds were not examined.

Conclusion: The order under section 263 was quashed as void ab initio and invalid in law.

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