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    <title>2026 (7) TMI 555 - ITAT MUMBAI</title>
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    <description>Reassessment proceedings initiated in the name of a deceased assessee were held invalid because the department had already recorded the death and the legal heir&#039;s registration on the Income Tax Portal had been approved before the reopening notices and orders were issued. Notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were all issued against the dead person, which went to the root of jurisdiction and amounted to a substantive illegality rather than a procedural defect. As the foundational notice was void, the later reassessment steps could not survive. The reassessment proceedings were quashed.</description>
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      <title>2026 (7) TMI 555 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=794669</link>
      <description>Reassessment proceedings initiated in the name of a deceased assessee were held invalid because the department had already recorded the death and the legal heir&#039;s registration on the Income Tax Portal had been approved before the reopening notices and orders were issued. Notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were all issued against the dead person, which went to the root of jurisdiction and amounted to a substantive illegality rather than a procedural defect. As the foundational notice was void, the later reassessment steps could not survive. The reassessment proceedings were quashed.</description>
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