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assessee in the quantum proceedings there is no dispute. The issue which devolves for our consideration is whether in the facts of the present case

sited in a representative character the person on whom the estate devolves on the dead) of the party so suing or sued. " In view

this was ancestral property inherited alongwith other relatives and which would anyway devolve to his only son and the property, thus, was HUF property

giving the assessee a reasonable time to address the issues which may devolve for consideration in the penalty proceedings. Said order was pronounced