2019 (7) TMI 992

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....case, where fate has overtaken normal time lines and normal life trajectories. 4. The writ petitioner before this Court is 24 years of age and he is pursuing his Master's degree(M.Tech). 5. Subject matter of this writ petition arises under the 'Income Tax Act, 1961' [hereinafter 'IT ACT' for brevity]. This writ petition pertains to Assessment Year 2010-2011 [hereinafter 'said AY' for brevity]. 6. There is no disputation or disagreement before this Court that qua said AY, writ petitioner was a minor and he was barely 16 years of age. 7. As mentioned in the prefatory paragraph of this order, this is a case where fate has overtaken the normal time lines and life trajectories of Nature. 8. This is a ca....

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.... to my Father, who had died on 6th June 2018 due to massive cardiac attack. ii) I am responding to this notice, since the same was addressed on my name. iii) During the Assessment Year 2011-12, I was doing my schooling and presently persuing my M.Tech degree. iv) My mother is a renal failure patient since more than a year and taking treatment at our native with the support of our grandparents. v) In general my father never used to discuss any business information neither to me nor to my mother being me a school going child and my mother is already with illness. vi) He was not so open to discuss any of his personal and business activities with us; but we were able to see, so often few of his busin....

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....#39;Show Cause Notice' ['SCN' for brevity] dated 26.12.2018 bearing reference PAN. ALPPC0202L/2018-19, which shall hereinafter be referred to as 'impugned SCN' for clarity and convenience. Annexures to the impugned SCN is an Assessment Order also dated 26.12.2018 qua said assessment year, wherein income tax was assessed at Rs. 25,62,337/-. Income Determined under Section 144 of the IT Act at Rs. 90,27,790/-. Added to it, is Education cess besides interests under Sections 234A and 234B, and the total payable amount is at Rs. 73,89,770/-. 13. What is of utmost importance is the positive and emphatic assertion of the writ petitioner that he has not inherited any property, cash deposits or movables from his father. This i....

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....t and the limitations if any, in this regard. Liability of legal representatives in such situations is adumbrated in Section 159 of the IT Act which in turn is under Chapter XV captioned 'LIABILITY IN SPECIAL CASES' and A thereunder is captioned 'Legal Representatives'. 19. Most relevant paragraph is Sub Section 6 of Section 159 of IT Act and the same reads as follows: 'CHAPTER XV LIABILITY IN SPECIAL CASES A.- Legal representatives Legal representatives. 159. (1)................ (2)................ (3)................ (4)................ (5)................. (6)The liability of a legal representative under this section shall, subject to the provi....