HC held that reassessment proceedings under s147 initiated...

HC held that reassessment proceedings under s147 initiated against a deceased assessee through notice issued post-death cannot be continued against legal representatives (LRs). While ongoing proceedings initiated during an assessee's lifetime may continue against LRs under s159(2)(b), new proceedings cannot commence after death. The court rejected Revenue's request for liberty to initiate fresh proceedings against LRs, noting no statutory obligation exists for LRs to inform Revenue about assessee's death. Additionally, if the limitation period for proceedings expired against the deceased, no action can be taken against LRs. The Income Tax Act 1961 contains no provision to exclude time spent during proceedings against deceased when calculating limitation period for LR proceedings. Appeal dismissed.

---