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of ITAT held reassessment proceedings invalid due to procedural irregularities. The Assessing Officer (AO) issued notice under Section 148 to a non-existent firm without properly serving legal heirs of deceased partners. Section 189(3) mandates that all legal heirs must be jointly and severally served and made parties to proceedings. Failure to issue comprehensive notices and implead all legal heirs rendered the entire reassessment process illegal and void. Procedural lapses in notice issuance and service constitute fundamental defects that compromise the legal validity of tax proceedings. Consequently, the assessee's appeal was allowed, effectively nullifying the reassessment order.
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