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The HC held that the assessment order under Section 144 read with Section 147 was invalid due to non-service of notice on the petitioners, who are the legal heirs of the deceased assessee. The respondent failed to produce evidence of proper service of notice, as only dispatch receipts from the Postal Department were available, lacking acknowledgment of receipt. The Court emphasized the necessity for the Income Tax Department to maintain integrated and reliable records of notice service akin to the Court's system. Since no proof of notice service on the petitioners was furnished and they were not brought on record as legal heirs, the orders passed against them without proper notice were quashed. The writ petition was allowed accordingly.
The HC held that the assessment order under Section 144 read with Section 147 was invalid due to non-service of notice on the petitioners, who are the legal heirs of the deceased assessee. The respondent failed to produce evidence of proper service of notice, as only dispatch receipts from the Postal Department were available, lacking acknowledgment of receipt. The Court emphasized the necessity for the Income Tax Department to maintain integrated and reliable records of notice service akin to the Court's system. Since no proof of notice service on the petitioners was furnished and they were not brought on record as legal heirs, the orders passed against them without proper notice were quashed. The writ petition was allowed accordingly.
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