2025 (8) TMI 1509

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....A)'] for the assessment year (AY) 2012-13. 2. The grounds of appeal raised by the assessee are as follows: "1. LD. CIT[A], NFAC, Delhi has erred in law and on fact to upheld AO's reopening of assessment u/s 147 and issue of a notice u/s 148 on date 27/03/2019 ignoring the fact that the said notice is not valid in law on account of notices's death on date 03/1/2025. 2. LD. CIT[A], NFAC, Delhi has erred in law and on fact to upheld AO's reopening as well as subsequent assessment proceedings valid in law ignoring the fact and law that initiation of proceedings upon dead person is not valid under the law." 3. The facts of the case in brief are that the assessee (Late Shri Gunvantrai Vasanji Desai - PAN: APKPD4488E) had n....

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....IT(A) reproduced the findings of AO at pages 4 to 8 of the appellate order. He set aside the order of AO passed u/s 144 r.w.s. 147 for making fresh assessment because the appellant had not furnished any documentary evidence during the assessment proceedings. 5. Aggrieved by the order of CIT(A), the assessee filed appeal before the Tribunal. The learned Authorized Representative (ld. AR) of the assessee submitted a paper book containing 20 pages including copy of submission made to CIT(A), letter dated 15.01.2015 to ITO, Ward-3 informing death of the assessee on 03.01.2015, reply to the AO dated 28.01.2015 with English translation, appellant's death certificate, notice u/s 148 dated 27.03.2019, notice u/s 142(1) on 30.11.2019, show cause ....