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    <title>2026 (2) TMI 1226 - ITAT INDORE</title>
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    <description>Reopening under the income-tax code must be premised on a valid foundational notice; a notice issued in the name of a person who had died before issuance is a nullity and cannot sustain proceedings. Where statutory rules permit liability to attach to legal heirs only if proceedings were initiated during the deceased&#039;s lifetime or a fresh notice is served on the heir, the absence of service on the legal heir defeats jurisdiction to proceed. Applying that principle, the reopening notice addressed to the deceased was invalid and consequent assessment proceedings could not be sustained against the legal heir.</description>
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    <pubDate>Mon, 28 Jul 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=787078</link>
      <description>Reopening under the income-tax code must be premised on a valid foundational notice; a notice issued in the name of a person who had died before issuance is a nullity and cannot sustain proceedings. Where statutory rules permit liability to attach to legal heirs only if proceedings were initiated during the deceased&#039;s lifetime or a fresh notice is served on the heir, the absence of service on the legal heir defeats jurisdiction to proceed. Applying that principle, the reopening notice addressed to the deceased was invalid and consequent assessment proceedings could not be sustained against the legal heir.</description>
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      <pubDate>Mon, 28 Jul 2025 00:00:00 +0530</pubDate>
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