2026 (2) TMI 490

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....NT.: This appeal, filed by the legal heirs of the deceased assessee, is directed against the order of the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi dated 15.03.2024 pertaining to the assessment year 2011-12. The assessee has raised the following grounds of appeal: - "1. Ld. CIT(A) erred while not allowing the cost of improvement of land ....

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....shed submissions. After considering the submissions and making necessary enquiries, the Assessing Officer adopted the stamp duty valuation u/s 50C of the Income-tax Act, 1961 ("Act" for short) and assessed the total income at Rs. 31,95,000/. Aggrieved by this, the assessee carried the matter before the Ld. CIT(A), who partly allowed the appeal of the assessee, thereby directed the Assessing Office....

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....the contention that the AO was justified in adopting the value of property on the basis of circle rate. 5. Heard the Ld. Representatives of the parties and perused the materials available on records. It is pointed out by the Ld. AR for the assessee that the impugned order has been passed against a dead person. Admittedly, the appeal before the Ld. CIT(A) was filed in the name of late Shri Chhed....

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.... before this Tribunal. Though, Form No. 36 was later revised and the thumb impression of the wife of the deceased assessee was appended on both the original as well as the revised Form No. 36, no formal substitution of legal heir was carried out. In view of these facts and circumstances, the impugned order cannot be sustained. As per Section 159(2a) of the Act, "any proceedings taken against the d....