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    <title>2026 (1) TMI 450 - ITAT AHMEDABAD</title>
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    <description>A reassessment initiated under s.147 was challenged on the ground that the s.148 notice was issued in the name of a deceased assessee. The Tribunal held that a notice to a dead person is a substantive jurisdictional defect and does not confer authority on the AO; under s.159, proceedings can be initiated only by issuing notice to the legal representative. It further held that s.292B cannot cure such illegality, and any alleged failure of the legal heir to intimate the death cannot validate a void notice; nor was there waiver or submission to jurisdiction. Consequently, the reassessment was void ab initio and the appeal was allowed.</description>
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    <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2026 (1) TMI 450 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=784694</link>
      <description>A reassessment initiated under s.147 was challenged on the ground that the s.148 notice was issued in the name of a deceased assessee. The Tribunal held that a notice to a dead person is a substantive jurisdictional defect and does not confer authority on the AO; under s.159, proceedings can be initiated only by issuing notice to the legal representative. It further held that s.292B cannot cure such illegality, and any alleged failure of the legal heir to intimate the death cannot validate a void notice; nor was there waiver or submission to jurisdiction. Consequently, the reassessment was void ab initio and the appeal was allowed.</description>
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      <pubDate>Fri, 28 Nov 2025 00:00:00 +0530</pubDate>
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