2025 (5) TMI 1966

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....ugh: 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 consequential demand notice of the same date, is....

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....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 21.02.2022 under Section 142 (1) of the Act were....

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....see 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 jurisdiction of an AO to commence proceedings. Absent ....