2026 (2) TMI 554

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.... No. CIT(A), Delhi-24/10411/2016-17 for A.Y. 2017-18. 2. The Assessee has raised following grounds of Appeal which are reproduced as below: "Addl. Ground No.1 1. That without prejudice, no incriminating material found and seized relating to issue of addition of Rs. 33,85,560/- u/s. 56(2)(vii) from assessee, therefore, at the most, this issue could had been examined only u/s. 153C. Regular Grounds 2. That in view of the fact that assessee died on 27.09.19 and the impugned asstt. being framed on the basis of notice u/s. 153A Dtd. 20.01.20 and notice u/s. 142(1) Dtd. 12.02.21, both issued in the name of dead assessee, the whole asstt. proceedings as well as impugned asstt. order is illegal and unsustainab....

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....before the Ld. CIT(A) which was dismissed vide order dated 08.08.2025. Aggrieved further, the assessee has filed an appeal before the Tribunal. Although several legal grounds have been raised by the assessee, we first take up Ground No. 2 relating to the validity of notice u/s 153A in the name of the deceased assessee. 4. Ld. AR has submitted before us that the assessee had expired on 27.09.2019 and notice u/s 153A was issued on 20.01.2020 in the name of the deceased. Another notice u/s 153A was issued on 20.01.2021 in the name of the legal heir, Ms. Poonam. Subsequently, notice u/s 142(1) was again issued in the name of the deceased. Finally, the assessment was framed in the name of Ms. Poonam L/H of Late Shri Kshitij Lal vide order u/s....