https://www.taxtmi.com/caselaws?id=375582 A reassessment notice issued under s. 148 in the name of a deceased assessee was held to be void ab initio because service on a "correct person" is a jurisdictional condition precedent to reopening, as s. 148 contemplates a notice capable of being responded to by a living assessee, i.e., the legal heir. The defect was held to be foundational and not a curable irregularity; consequently, ss. 292B and 292BB could not validate the notice or confer jurisdiction. The HC therefore quashed the impugned s. 148 notice and the consequential order, while clarifying that the Revenue may issue a fresh notice in accordance with ss. 147/148 and within limitation. en-us Fri, 15 Feb 2019 00:00:00 +0530 Mon, 27 Jul 2026 14:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375582 A reassessment notice issued under s. 148 in the name of a deceased assessee was held to be void ab initio because service on a "correct person" is a jurisdictional condition precedent to reopening, as s. 148 contemplates a notice capable of being responded to by a living assessee, i.e., the legal heir. The defect was held to be foundational and not a curable irregularity; consequently, ss. 292B and 292BB could not validate the notice or confer jurisdiction. The HC therefore quashed the impugned s. 148 notice and the consequential order, while clarifying that the Revenue may issue a fresh notice in accordance with ss. 147/148 and within limitation. Case-Laws Income Tax Fri, 15 Feb 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375582