2022 (12) TMI 1605

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....RISHI, AM: 01. This appeal is filed by Mr. Suhail Siddiqui in ITA No.1179/Mum/2022 against the revisionary order passed by the Pr. Commissioner of Income Tax under Section 263 of the Income-tax Act, 1961 (the Act) in the name of Late Mr. Mohammad Sharif Siddique for A.Y. 2017-18 on 29th March, 2022 wherein the learned PCIT held that assessment order passed under Section 143(3) of the Act dated ....

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....ent order was passed wherein the addition of Rs.19,10,000/- was made in the hands of the assessee as unexplained money, being cash deposited in the assessee's bank account. The assessment order was passed on 17th December, 2019 in the name of late Mr. Mohammad Sharif Siddique determining total income of Rs. 20,30,740/-. 04. The learned PCIT on examination of the record that the learned Assessin....

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....ith the above order and filed this appeal. The first ground raised is that the 263 order is invalid as same is passed in the name of deceased person. It was also stated that assessment order is also passed in the name of dead person. 06. At the time of hearing, none appeared on behalf of the assessee. Therefore, this appeal is decided on the basis of information available on record. 07. The ....

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....d in the assessment order itself. Despite this fact, the learned PCIT passed the order in the name of deceased assessee. Further, the notice for hearing under Section 263 of the Act dated 24th February, 2022 was also issued in the name of dead person. Thus, where the notices were issued to the assessee under Section 263 of the Act after his death the notice could not have been validly served upon ....