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5.7 There cannot be an assessment against the dead person. As noticed above, the provisions of Section 292B of the Act are also not applicable and no assessment can be framed against a nonexisting entity or a person who has died."

5.2 In light of the above law, reverting back to the facts of the present case, assessee-Gordhandas Madhavji Somaiya died on 20.08.2019. Notice under section 148 of the Income Tax Act came to be issued on 30.3.2021, that is after about nineteen months from the death of the assessee.