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12. A similar controversy arose before a Division Bench of this Court in the case of Gokul Chand v. ITO (1995) 211 LTR 738 (All). It has been held that where a reassessment notice has been issued to a person in his individual capacity, the notice is invalid as it does not mention that it was being issued to the person in his capacity as the Karta of "HUF".

13. In CIT v. Ishwar Singh & Sons (supra), it was held by this Court that a notice under Section 148 was issued to an entity which was, as a matter of fact, nonexistent and was at any rate different from the entity which filed return in response to that notice. The notice was issued to Sardar Arjun Singh, an individual, and the return was filed by Sardar Sampuran Singh, Karta of HUF. The two are distinct entities in law, as also, as matter of fact and thus a valid reassessment could not be made on the assessee-HUF, as no notice had been issued to it under Section 148 of the Act.