Assessment proceedings conducted in the name of a deceased...

Assessment proceedings conducted in the name of a deceased taxpayer where no verifiable intimation of death or PAN surrender was placed on record do not render the assessment void ab initio; the defect is an irregularity curable by bringing the legal heirs on record and rectification under succession provisions (section 159) is appropriate. The administrative officers lack of knowledge of death is excused where legal heirs failed to promptly notify authorities, and precedent treating assessments on deceased persons as irregular rather than illegal supports rectification to bind legal heirs on record.

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