Reassessment notices to deceased assessees are invalid, requiring proceedings to begin directly against legal representatives.

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....Reassessment notices issued to deceased assessees are invalid because the legal-representative provisions permit either continuation of proceedings started during the assessee's lifetime or fresh proceedings directly against the legal representative; they do not permit a notice to be issued in the deceased person's name and later continued against an heir. Consequently, reassessment founded on such a notice is unsustainable and must be quashed. Where jurisdiction fails at the notice stage, challenges to the underlying additions need not be adjudicated and remain open.....