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    <title>Reassessment Notices Issued to Deceased Assessees Are Jurisdictionally Invalid and Require Proceedings Against Legal Representatives</title>
    <link>https://www.taxtmi.com/highlights?id=103335</link>
    <description>Reassessment initiation against a deceased assessee is jurisdictionally defective where the show-cause notice is issued after death. Service of a show-cause notice is a condition precedent to an order under Section 148A(3) and a reassessment notice under Section 148; a notice issued to a dead person is non-est and cannot be cured through later proceedings against the legal representative. Section 159 requires reassessment proceedings concerning a deceased person&#039;s income to be instituted against the legal representative and does not validate proceedings begun against the deceased, particularly where the Department knew of the death. Participation after a jurisdictional objection does not confer jurisdiction. Consequential proceedings may be quashed, without barring fresh lawful proceedings within limitation.</description>
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    <pubDate>Wed, 02 Sep 2026 08:30:15 +0530</pubDate>
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      <title>Reassessment Notices Issued to Deceased Assessees Are Jurisdictionally Invalid and Require Proceedings Against Legal Representatives</title>
      <link>https://www.taxtmi.com/highlights?id=103335</link>
      <description>Reassessment initiation against a deceased assessee is jurisdictionally defective where the show-cause notice is issued after death. Service of a show-cause notice is a condition precedent to an order under Section 148A(3) and a reassessment notice under Section 148; a notice issued to a dead person is non-est and cannot be cured through later proceedings against the legal representative. Section 159 requires reassessment proceedings concerning a deceased person&#039;s income to be instituted against the legal representative and does not validate proceedings begun against the deceased, particularly where the Department knew of the death. Participation after a jurisdictional objection does not confer jurisdiction. Consequential proceedings may be quashed, without barring fresh lawful proceedings within limitation.</description>
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      <pubDate>Wed, 02 Sep 2026 08:30:15 +0530</pubDate>
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