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A reassessment notice under Section 148 must be issued to a living and correctly identified assessee; a notice issued to a deceased person is void from inception. Proceedings may continue against a legal representative only if validly initiated during the deceased's lifetime, while fresh proceedings require a notice directly to the legal representative within the statutory limitation period. Section 292B cannot cure this foundational jurisdictional defect, and Section 292BB does not apply where the assessee died before notice issuance; participation or waiver cannot confer jurisdiction. Equitable considerations cannot validate the proceedings. Quashing the void notice is not a finding or direction under Section 150 permitting a time-barred fresh reassessment notice.
A reassessment notice under Section 148 must be issued to a living and correctly identified assessee; a notice issued to a deceased person is void from inception. Proceedings may continue against a legal representative only if validly initiated during the deceased's lifetime, while fresh proceedings require a notice directly to the legal representative within the statutory limitation period. Section 292B cannot cure this foundational jurisdictional defect, and Section 292BB does not apply where the assessee died before notice issuance; participation or waiver cannot confer jurisdiction. Equitable considerations cannot validate the proceedings. Quashing the void notice is not a finding or direction under Section 150 permitting a time-barred fresh reassessment notice.
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