Proceedings against a deceased assessee are void when initiated after death; legal representatives can be proceeded against only in valid continuation.

Assessment and demand proceedings issued in the name of a person after death are a foundational jurisdictional defect and are not cured as a procedural irregularity. Section 159 permits action against legal representatives only where proceedings were validly initiated during the assessee's lifetime and then continued after death; it does not authorise fresh proceedings against a deceased person. The notices under Section 148A(d) and the consequential assessment and demand notices, having been issued after the assessee's death, were therefore invalid and unsustainable, and the challenge succeeded.

---

---

Issues: Whether assessment and demand proceedings initiated in the name of a person who had already died are valid, and whether the legal representatives can be proceeded against under the statutory scheme only in continuation of proceedings lawfully initiated during the lifetime of the deceased.

Analysis: The proceedings under Section 148A(d) and the consequential assessment and demand notices were issued after the assessee's death. The statutory scheme under Section 159 permits action against legal representatives where proceedings are continued after having been validly initiated while the assessee was alive, but it does not authorise fresh proceedings in the name of a deceased person. A notice issued to a dead person is a foundational jurisdictional defect and cannot be cured as a mere procedural irregularity.

Conclusion: The proceedings initiated against the deceased assessee were invalid and unsustainable. The challenge succeeded, and the orders and notices were set aside.

---