2025 (2) TMI 1816

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.... Sinha, Adv. For the Respondent : Sh. Sukesh Kumar Jain, CIT(DR) ORDER PER SATBEER SINGH GODARA, JM The appellant herein Sh. Pradeep Jain (alleged legal heir of Late Sh. Jay Narayan) has filed his instant five appeals ITA Nos.334, 335, 336, 337 and 338/Agr/2024 for assessment years 2013-14 to 2017-18, against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appea....

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....ts in his hands, involving varying sums, respectively in his hands. 4. This being the clinching backdrop involved herein, we sought to know from the Revenue side as to whether this appellant Sh. Pradip Jain has succeeded to the estate of the deceased assessee or not so as to be held as the "legal representative" as defined under section 2(29) of the Act adopting statutory definition given in se....

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....is managing the same or an intermeddler thereof, as the case made be. 6. Faced with this situation, we hereby adopt stricter construction as per Commissioner vs. Dilip Kumar And Co. & Ors. [2018] 9 SCC 1 (SC) (FB) to treat that both the learned lower authorities' impugned action/proceedings against the assessee having status of mere "legal heir" than the specific "legal representative" of the d....