Assessment Reopening Invalid: Section 147 Notice Issued Incorrectly as Legal Heir, Not Individual, u/s 148.

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....Reopening of assessment u/s 147 - Legality of assessment framed in the capacity of legal heir - notice u/s 148 was issued in individual capacity and the assessment was framed in the capacity of legal heir. - Since the notice does not meet the requirement of law, therefore, we are of the considered view that the re-opening of assessment is bad in law and the impugned assessment made by the AO cannot be sustained. - AT....