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    <title>2025 (2) TMI 1816 - ITAT AGRA</title>
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    <description>Reassessment proceedings could not be sustained against a person merely described as a legal heir, where there was no finding that he was the legal representative of the deceased assessee or that the deceased&#039;s estate had devolved upon him. The statutory liability of a legal representative extends only to the value of the estate represented, and the term must be understood as a person in law representing that estate. On strict construction, mere heirship was insufficient to fasten reassessment liability. The proceedings were therefore unsustainable in law.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468603</link>
      <description>Reassessment proceedings could not be sustained against a person merely described as a legal heir, where there was no finding that he was the legal representative of the deceased assessee or that the deceased&#039;s estate had devolved upon him. The statutory liability of a legal representative extends only to the value of the estate represented, and the term must be understood as a person in law representing that estate. On strict construction, mere heirship was insufficient to fasten reassessment liability. The proceedings were therefore unsustainable in law.</description>
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