Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Notice issued to a deceased person is void ab initio, and all consequential reassessment proceedings fail for want of jurisdiction. The Court applied the principle that proceedings initiated after the assessee's death cannot be validated by the machinery for legal representatives; that mechanism operates only where proceedings were already commenced during the assessee's lifetime. Because the reassessment-related proceedings were admittedly initiated after death, the defect went to the root of the matter and the entire action was set aside.
Notice issued to a deceased person is void ab initio, and all consequential reassessment proceedings fail for want of jurisdiction. The Court applied the principle that proceedings initiated after the assessee's death cannot be validated by the machinery for legal representatives; that mechanism operates only where proceedings were already commenced during the assessee's lifetime. Because the reassessment-related proceedings were admittedly initiated after death, the defect went to the root of the matter and the entire action was set aside.
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