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"Once it is found that assessment is framed in the name of nonexisting entity, it does not remain a procedural irregularity of ht nature which could be cured by invoking the provisions of section 292V of the Act."

12. The Hon'ble High Court further held that the framing of assessment against a non-existing entity/person goes to the root of the matter which is not a procedural irregularity but a jurisdictional defect as there cannot be any assessment against a dead person.

13. The Co-ordinate Bench of the Tribunal in the case of M/s Images Credit and Portfolio [P] Ltd in ITA Nos. 5301 to 5306 and ITA No. 5418/DEL/2013 dated 19.12.2014 on identical set of facts has held as under: