Reopening assessments beyond four years requires nondisclosure of material facts; mere change of opinion or general allegations invalidates reassessme...
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Proceedings originally instituted against a taxpayer who died during appeal must be treated as proceedings against the legal representative; absence of formal substitution and failure to notify appellate authorities vitiated continuation. The Tribunal applied the statutory principle that proceedings pending at death are deemed taken against the legal representative and therefore held the appellate authority should have proceeded against the legal representative. Consequence: impugned order set aside and grounds remitted to the appellate authority to decide afresh against the legal representative; the appeal was allowed for statistical purposes.
Proceedings originally instituted against a taxpayer who died during appeal must be treated as proceedings against the legal representative; absence of formal substitution and failure to notify appellate authorities vitiated continuation. The Tribunal applied the statutory principle that proceedings pending at death are deemed taken against the legal representative and therefore held the appellate authority should have proceeded against the legal representative. Consequence: impugned order set aside and grounds remitted to the appellate authority to decide afresh against the legal representative; the appeal was allowed for statistical purposes.
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