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2022 (11) TMI 24 - HC - Income TaxReopening of assessment u/s 147 - Notice issued to the deceased assessee during her lifetime - HELD THAT:- Since the present assessment proceedings are in continuation of the initial notice dated 25th April, 2021, issued to the deceased assessee during her lifetime, the same can be continued against the legal representative from the stage at which it stood on the date of the death of the deceased so as to collect the tax from the estate of the deceased person. Initial notice was issued at the time when the assessee was alive (the present proceedings are in continuation) and thus, the AO has rightfully amended the details of the addressee in its consequent order under Section 148A(d) and notice under Section 148 of the Act. The reliance placed by the assessee on the decision of this Court in Sangeeta Vig [2022 (6) TMI 658 - DELHI HIGH COURT] in misplaced since in that case the initial notice under the erstwhile Section 148 of the Act, was issued at a time when the assessee was dead. However, in the present case, as noted above, the assessee was alive at the time of the issuance of initial notice under erstwhile Section 148 of the Act.
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