https://www.taxtmi.com/caselaws?id=798121 Service of a show-cause notice under Section 148A(1) on the correct person is a jurisdictional precondition for an order under Section 148A(3) and a reopening notice under Section 148. Initiating reassessment against a deceased assessee is invalid where the Department had already registered the legal heir. Section 159 permits proceedings against a legal representative but does not permit initiation against a deceased person followed by substitution of the legal representative. The legal heir's participation and jurisdictional objection cannot cure the foundational defect, rendering the consequential reassessment proceedings unsustainable. en-us Sat, 29 Aug 2026 00:00:00 +0530 Wed, 02 Sep 2026 08:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798121 Service of a show-cause notice under Section 148A(1) on the correct person is a jurisdictional precondition for an order under Section 148A(3) and a reopening notice under Section 148. Initiating reassessment against a deceased assessee is invalid where the Department had already registered the legal heir. Section 159 permits proceedings against a legal representative but does not permit initiation against a deceased person followed by substitution of the legal representative. The legal heir's participation and jurisdictional objection cannot cure the foundational defect, rendering the consequential reassessment proceedings unsustainable. Case-Laws Income Tax Sat, 29 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798121