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    <title>2024 (2) TMI 836 - ITAT RAJKOT</title>
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    <description>An assessment framed in the name of a deceased assessee, without bringing the legal heirs on record, is invalid in law and treated as a nullity. The text notes that there was no material showing substitution of the heirs, and that no statutory duty required them to intimate the department about the death. Because the foundational assessment itself was jurisdictionally defective, section 263 could not be used to revise, cure, or sustain it. The defect was held to affect all consequential proceedings, and the revision was stated to be invalid and liable to be set aside in favour of the assessee.</description>
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      <description>An assessment framed in the name of a deceased assessee, without bringing the legal heirs on record, is invalid in law and treated as a nullity. The text notes that there was no material showing substitution of the heirs, and that no statutory duty required them to intimate the department about the death. Because the foundational assessment itself was jurisdictionally defective, section 263 could not be used to revise, cure, or sustain it. The defect was held to affect all consequential proceedings, and the revision was stated to be invalid and liable to be set aside in favour of the assessee.</description>
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