Reassessment against a deceased assessee is a jurisdictional nullity when notices are issued after death is recorded.

Reassessment proceedings initiated in the name of a deceased assessee were held invalid because the department had already recorded the death and the legal heir's registration on the Income Tax Portal had been approved before the reopening notices and orders were issued. Notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were all issued against the dead person, which went to the root of jurisdiction and amounted to a substantive illegality rather than a procedural defect. As the foundational notice was void, the later reassessment steps could not survive. The reassessment proceedings were quashed.

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Issues: Whether reassessment proceedings initiated and continued in the name of a deceased assessee were valid in law.

Analysis: The legal heir's registration on the Income Tax Portal had already been approved and the department's records reflected the death of the assessee before the reopening notices and consequential orders were issued. Notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were all issued in the name of the deceased. Such initiation of proceedings against a dead person was held to strike at the root of jurisdiction and was treated as a substantive illegality, not a mere procedural irregularity. Once the foundational notice was invalid, the later reassessment steps could not survive.

Conclusion: The reassessment proceedings were quashed as invalid, and the assessee succeeded on the jurisdictional challenge.

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