2025 (5) TMI 1966

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....AS KARIA For the Petitioner Through: Mr. Samarendra Kumar, Advocate. For the Respondent Through: Mr. Vipul Agrawal, SSC with Ms. Sakshi Sehrawal, JSC, Mr. Akshat Singh, JSC and Mr. Gaoraang Ranjan, Advocate. VIBHU BAKHRU, J. (ORAL) 1. The petitioner has filed the present petition, inter alia, impugning an assessment order dated 30.03.2022 [the impugned assessment order] and the consequ....

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.... PAN details of the deceased Assessee, his own PAN, the death certificate of the Assessee, and a letter issued by the Indian Bank certifying the petitioner as the nominee of the deceased Assessee. 3. On 31.03.2021, a notice under Section 148 of the Act was issued in the name of the deceased Assessee, seeking to reopen the assessment for AY 2014-15. Subsequently, notices dated 25.01.2022 and 21.....

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....gistered as the legal representative of the Assessee and therefore, the AO was not precluded from initiating proceedings against the petitioner in a representative capacity. However, it is clear that no such proceedings were issued. 6. We are unable to accept that the defect in the present case can be overlooked, as the issuance of a notice under Section 148 of the Act is at the root of the jur....