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Facts
The assessee did not file a return for A.Y. 2017-18, made significant cash deposits during demonetization, and sold an immovable property without declaring capital gains. The Assessing Officer initiated assessment proceedings, but the assessee expired during the process. Despite receiving the death information, the AO completed an ex-parte assessment, making substantial additions.
Held
The CIT(A) quashed the assessment order as void ab initio, ruling it invalid because it was passed against a deceased person. The Tribunal, however, relying on Section 159 of the Income-Tax Act, held that since the initial notice was issued when the assessee was alive, the proceedings could be continued against the legal representatives. Consequently, the Tribunal set aside the CIT(A)'s order and restored the matter to the AO with a direction to pass a fresh assessment order against the legal heir after providing due opportunities.
Key Issues
The key legal issue was the validity of an assessment order passed against a deceased person when the initial notice was served during their lifetime, and whether such proceedings could be continued against their legal representatives under Section 159 of the Income-Tax Act, 1961.
Sections Cited
144, 142(1), 159, 139(1), 69A, 115BBE, 148A(d), 148, 260(1)
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Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD
Before: SHRI T.R. SENTHIL KUMAR & SHRI MAKARAND V. MAHADEOKAR
IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD \ BEFORE SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER Assessment Year : 2017-18 Income-Tax Officer, Haresh Dayashankar Shrivastav, Vs Ward 3(3)(1), 35, Swetanjali Society, Nr. Ahmedabad Hasubhai Park, Satellite, Ahmedabad-380015 PAN : BBPPS 5719 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Arsh Shaikh, AR Revenue by : Shri Abhijit, Sr DR सुनवाई क" तार"ख/Date of Hearing : 25.06.2025 घोषणा क" तार"ख /Date of Pronouncement : 24.07.2025 आदेश / O R D E R PER T.R. SENTHIL KUMAR, JUDICIAL MEMBER :
This appeal is filed by the Revenue as against the appellate order dated 22.01.2025 passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi, (hereinafter referred to as “CIT(A)”), arising out of the ex-parte assessment order passed under Section 144 of the Income-Tax Act, 1961 (hereinafter referred to as “the Act”), relating to the Assessment Year 2017-18.
The brief facts of the case are that the assessee is an individual who has not filed his return of income for A.Y. 2017-18, whereas the assessee made cash deposits of Rs.1,58,43,170/- during demonetization period. Further there was credit entries reflected in his bank account of Rs.69,98,368/- and the assessee sold an immovable property on 04.06.2016 for a consideration of Rs.1 crore, ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 2 but the assessee has not offered capital gains thereon. Therefore, the Assessing Officer issued a notice u/s.142(1) through ITBA portal on 29.12.2017 to file the Return of Income for A.Y.2017-18, which was duly served upon the assessee. The assessee neither responded to the notice nor filed his return of income; therefore, further notices u/s.142(1) of the Act dated 11.06.2019 and 11.09.2019 were issued with a request to furnish necessary details/documents. Again, there was no response from the assessee, therefore a final show-cause notice dated 19.09.2019 was issued to furnish necessary details/ documents for the purpose of proceedings with the assessment. In response, assessee’s wife furnished a written submission stating that her husband expired on 27.08.2019, enclosing therewith the death certificate of the assessee and also stated that she did not aware about any financial transactions made by her deceased husband/assessee, hence, unable to file the required details. The Assessing Officer considered the above submission of the legal-heir of the assessee and proceeded with passing of an ex-parte assessment order by making addition of Rs.3,28,41,538/- in the name of the deceased-assessee and demanded tax thereon.
Aggrieved against the ex-parte assessment order, the legal-heir filed an appeal before the Ld. CIT(A). After considering the submissions made on behalf of the assessee, the Ld. CIT(A) quashed the assessment order on the ground that it was passed against a dead person, rendering it nullity and void ab initio. The Ld. CIT(A) observed as follows::-
6.2 During the appellate proceedings, the representative of the appellant (deceased) has made submissions along with death certificate of the appellant, which are duly considered and hereby accepted. As per statement of facts, it is seen that the appellant had ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 3 expired on 27.08.2019, which is much before the assessment proceedings i.e. 14.12.2019. It is seen that notice u/s 142(1), dated 11th September 2019 and also show Cause Notice u/s 144, dated 9th October 2019 were issued to a person who was deceased. It is also seen from the assessment order that the appellant's wife brought to the AO's notice that the appellant had expired on 27.08.2019 and filed copy of death certificate, which had been acknowledged by the AO at para no. 8 of the assessment order. Still the Assessing Officer has passed the order against a deceased person. It is pertinent to mention here that the Ld AO failed to complete the assessment proceedings in the hands of legal heir of the deceased appellant under the provision of the I.T Act, 1961. Therefore, the entire assessment proceedings becomes a nullity and void ab-initio. I hereby delete the addition of Rs.3,28,41,538/- as made by the A.O. in the assessment order as discussed above.
4. Aggrieved against the appellate order, the Revenue is in appeal before us raising the following grounds of appeal:-
“(a) The Ld.CIT(A) has erred in law and on facts in quashing the assessment and deleting various additions totalling to Rs. 3,28,41,538/-, without appreciating that: (i) The assessment proceedings was initiated vide notice u/s. 142(1) of IT Act dated 29.12.2017, which was duly served upon the assessee. (ii) During the assessment proceedings, the legal heir did not furnish any submission except stating that the assessee has expired on 27.08.2019. Further, the legal heir did not take any steps for registration herself as a legal heir for assessment. (b) The Ld.CIT(A) has erred in law and on facts in not deciding the appeal on merits of the case. (c) The Ld. CIT(A) ought to set aside the assessment order to the file of the AO to pass the assessment order after taking the legal heir on record. (d) The appellant craves leave to add, alter and /or to amend all or any the ground before the final hearing of the appeal.” ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 4 5. The Ld. Sr. DR Shri Abhijit, appearing for the Revenue, submitted that the assessee is an individual who was regularly filing his returns upto AY 2016-17. However, for the present Assessment Year A.Y. 2017-18 has not filed his return of income u/s 139(1) of the Act, whereas the assessee made cash deposit of Rs.1.58 crores in his bank accounts during demonetization period. Further, the assessee sold an immovable property on 04.06.2016 for a consideration of Rs.1 crore but not offered Long Term Capital Gain. Since the assessee has not filed the regular return of income for the year under consideration, the Assessing Officer issued a notice u/s 142(1) of the Act through ITBA portal on 29.12.2017 which was duly served upon but the assessee has not filed return of income. Therefore, further notices u/s 142(1) dated 11.06.2019 and 11.09.2019 were also issued by the Assessing Officer. However, as against the final show-cause notice dated 19.09.2019, the assessee was requested to file its reply on or before 14.10.2019 at 11.00 AM, either personally or through Authorized Representative. In response, assessee’s wife furnished a written submission stating her husband expired on 27.08.2019 and furnished copy of the Death Certificate of the assessee and further stated that she did not aware about any financial and other transactions made by her husband and unable to furnish the required details. Thereafter, the Ld AO passed the assessment order, treating the cash deposit made during demonetization period of Rs.1,58,43,170/- as unexplained money u/s 69A of the Act and charged to tax u/s 115BBE of the Act.
5.1 The Ld AO also made the other credit entries reflected in the bank account at 8% and made addition of Rs.69,98,368/- and also Short Term Capital Gains of Rs.1 Cr., thereby assessed the total income at Rs.3,28,41,538/- and demanded tax thereon. Thus, the ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 5 Ld. Sr. DR submitted that the date of death of the assessee was 27.08.2019 only, whereas the assessee is required to file his return of income before 30.09.2019, which was not done by the assessee, when notices u/s.142(1) dated 29.12.2017 and 11.06.2019 were duly served upon the assessee, he failed to file the return of income. Thus, the assumption of jurisdiction for assessment is well within the provisions of law. Therefore, the Ld. CIT(A) erred in quashing the assessment order on a dead person is legally not sustainable in law and he relied upon decision of Hon’ble Delhi High Court in the case of Vijay Garg Vs. ITO, reported in [2023] 146 taxmann.com 231 (Delhi) and also relied upon Co-ordinate Bench decision in the case of Late Shri Keshavlal Somnath Panchal Vs. ITO in 2020 dated 16.03.2020. The Ld. Sr. DR also produced before us one FAQs issued by the department on how to register a Representative Assessee through e-Filing and thereby requested to set aside the impugned order to the file of JAO to pass order on merits.
Per contra, Ld. Counsel Shri Arsh Shaikh, appearing for the assessee, submitted before us, an affidavit filed by the legal-heir of the deceased-assessee and also Affidavits of other legal-heirs of the deceased assessee viz. his mother Smt. Kalavatiben Shrivastav and daughter aged 19 years, Ms. Pushti Haresh Shrivastav deposing “no objection” to Ms. Kajal Shrivastav wife of the deceased in representing the estate of the deceased assessee as Class-I legal heirs of the deceased.
6.1. Ld. Counsel for the assessee relied upon the Hon’ble Supreme Court decision in the case of PCIT Vs. Maruti Suzuki India Ltd wherein held that assessment passed on dead person is invalid in law and Hon’ble Madras High Court judgment in the case of Alamelu ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 6 Veerappan Vs. ITO, reported in [2018] 102 CCH 118, wherein it was held that there is no statutory obligation on the part of the legal representative of the deceased assessee to immediately intimate the death of the assessee or take steps to cancel the PAN registration of the deceased.
6.2. Ld. Counsel for the assessee further placed reliance on the judgement of Hon’ble Supreme Court in the case of CIT Vs. Amarchand N. Shroff, reported in [1963] 48 ITR 59 (SC), wherein it was held that the proceedings are void, if issued in name of dead person and the legal representative is liable only to the extent of the estate of the deceased. The Ld. Counsel also relied upon various other case-laws in similar lines and pleaded to confirm the appellate order passed by the Ld CIT[A] and dismiss the Revenue appeal.
We have heard the rival contentions and perused the material available on record, including the case-laws cited by both parties. It is undisputed fact that the assessee has not filed his return of income well within the time or belatedly as described by the Assessing Officer at page No.7 of the assessment order. Since the assessee failed to file the return of income, the Ld AO issued a notice u/s.142(1) of the Act dated 29.12.2017 which was duly served on the assessee; however, the assessee neither replied to the notice nor filed the return of income, when the assessee was very much alive. Therefore, the AO issued further notices u/s.142(1) of the Act dated 11.06.2019 and 11.09.2019 in the name of the assessee and assumed jurisdiction to assess the income. However, pursuant to the final show-cause notice, the assessee’s wife replied that the assessee expired on 27.08.2019 and claimed that she did not aware about the financial transactions made by her deceased husband and unable to furnish the required ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 7 details. Thus the Assessing Officer assumed jurisdiction by issuing notice u/s.142[1] dated 29.12.2017 much before the date of death of the assessee on 27.08.2019. Further, the assessee neither filed the Return of Income voluntarily u/s.139 of the Act nor pursuant to the notice issued by the AO to file the Return of Income for the A.Y. 2017- 18. Thus, the assessee miserably failed to discharge the primary onus cast upon him and therefore the assessment order cannot be void ab- initio.
7.1 The assessment in the case of legal representative is dealt in Section 159 of the Act, which has self contained mechanism for continuing assessment proceedings and recovering tax from the legal representative of a deceased assessee, which can be summarized as follows:
Sub- Provision Explanation section The legal heir inherits not Where an assessee dies, his legal just property, but also (1) representative shall be liable to pay tax liability to the extent any sum that the deceased would of the estate. have been liable to pay. Any proceeding taken against the Ongoing assessments deceased before his death may be don’t restart — they (2) continued against the legal continue seamlessly representative from the stage at against the heir. which it stood. He stands in the shoes of Legal representative shall be deemed (3) the deceased for tax to be an assessee for purposes of matters. such proceedings. If the legal representative parts with Prevents evasion by (4) or disposes of any assets, his liability transferring assets. is limited to the value of assets handled. ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 8 Sub- Provision Explanation section The department can recover tax dues Power of recovery from (5) from property under the control of inherited estate. the legal representative. The liability of the legal representative He is not personally liable (6) is limited to the estate inherited beyond what he inherits. and does not extend to personal assets.
7.2. As per sub-section 2 of Section 159 any proceeding taken against the deceased before his death may be continued against the legal representative from the stage at which it stood. As per sub-section 3, Legal representative shall be deemed to be an assessee for purposes of such proceedings. As per sub-sections 1 and 6 of section 159, where an assessee dies, his legal representative shall be liable to pay any sum that the deceased would have been liable to pay but the liability of the legal representative is limited to the estate inherited and does not extend to personal assets. Reading of the above provisions, in our considered view, the Ld CIT[A] has not considered the above provision as well as non-filing of return by the assessee for this Asst. year 2017-18 during his life time voluntarily and inspite of service of notice u/s.142[1] of the Act. Further Ld CIT[A] relied upon the case laws which are clearly not applicable/distinguishable to the facts of the present case and erroneously held that the assessment is void ab-initio.
7.3. Ld SR DR rightly relied upon the Hon’ble Delhi High Court judgement in the case of Vijay Garg Vs. ITO, [cited supra] wherein it was held as under:- ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 9 “7.3. 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. The Supreme Court in the case Shabina Abraham v. Collector of Central Excise & Customs [2015] 61 taxmann.com 95/34 GSTR 146/52 GST 30/83 VST 450/2015 10 SCC 770 has concisely explained the said provision as under: "16. It will be noticed that under section 159(2), for the purpose of making any assessment, any proceeding taken against the deceased before his death is by deeming fiction deemed to have been taken against his legal representative and may be continued against the legal representative from the stage at which it stood on the date of the death of the deceased. Further, the legal representative under sub-section (3) of section 159 is again by deeming fiction deemed to be an assessee himself. However, the liability of such representative is limited only to the extent to which the estate left by the deceased is capable of meeting the tax liability subject to the contingencies mentioned in sub-sections (4) and (5) of section 159."
8. Therefore, in light of the aforesaid provision, since, the initial notice dated 25th April, 2022, 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.
9. Further, the reliance placed by the assessee on the decision of this Court in Sangeeta Vig (supra) 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.”
7.4. The Ld. SR DR also relied upon the decision of the Co-ordinate Bench of this Tribunal in the case of Late Shri Keshavlal Somnath Panchal Vs. ITO in dated 16.03.2020, wherein it was held as under:-
“7. We have considered rival submissions and gone through the record carefully. We find that before service of notice under section 142(1) Shri Keshavlal Somnath Panchal had already expired. His legal heirs did not file return for this assessment year. Therefore, the right course for the AO is to find out L/Rs, and more particularly, L/R who has inherited assets and ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 10 liabilities of Shri Keshavlal Somnath Panchal because L/R is liable to pay taxes of the deceased only equivalent to the property inherited from the deceased. For example, in the present case, if the assessment order is finalized, but later on Smt. Champaben Keshavlal Patel comes forward and states that she has not inherited any property from Shri Keshavlal Somnath Panchal, then demand cannot be recovered. Other L/Rs. if any would take an objection that they have not served any notice under section 142(1) or under section 148 etc. Therefore, procedure followed by the AO in the present case is patently illegal. Service of notice upon a dead person under section 142(1) would not authorise him to assume jurisdiction to pass assessment order on the L/Rs. also. The right course for him is to explore jurisdiction for issuing a notice on the L/Rs. of Shri Keshavlal Somnath Panchal. This aspect could have been examined by the ld.CIT(A). Had she gone through written submissions taken note in para -2 of the impugned, wherein it was alleged that Shri Keshavlal Somnath Panchal died on 2.10.2017, then his appeal could have been allowed to be entertained manually as provided in Rule 45 and 12 of the Income Tax Rules.
8. After going through the above provisions, and keeping in mind note placed by the ld.counsel for the assessee explaining the procedure required to be followed in the present case, we are satisfied that ld.CIT(A) ought to have entertained the present appeal, and should have decided on merit. Therefore, we set aside the orders of the ld.CIT(A) and restore the issue to the file of the ld.CIT(A) for re-adjudication.
The observation made by us for explaining the position contemplated in section 159 of the Income Tax Act for assessing the legal heirs will not impair or injure the case of the AO, and will not cause any prejudice to the defence/explanation of the assessee or other legal heirs in future. This observation is made only for the purpose of explaining the situation.” 7.5. The Ld. Sr. DR also produced before us FAQs to register a Representative Assessee with the Income-tax Department through e- Filing, the relevant part reads as follows:-
“ Question 4: Who can register as a Representative Assessee? What are the required documents an individual need to furnish to be a Representative Assessee? Resolution: The below table lists the cases where one can register as Representative Assessee along with the documents to be furnished: ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 11 S. Category of Who shall no. Person being Register as Documents Required represented Representative As court of Administrator • Copy of PAN card of the person for 1 wards General / whom Court of Wards is appointed Official Trustee • Copy of Court Order appointing Court / Receiver / of wards/ Receiver/Manager/ Manager who Administrator General/Official manages the Trustee property Deceased Legal heir of the • Copy of PAN Card of the deceased 2 (Legal heir) deceased person • Copy of Death Certificate • Copy of Legal heir proof as per the norms • Copy of the order passed in name of the deceased (Mandatory only if the reason for registration is ‘Filing of an appeal against an order passed in the name of deceased’) • Copy of Letter of Indemnity (optional)
Lunatic or Guardian / • Copy of PAN card of the lunatic/Idiot 3 Idiot Manager who is person managing the • Certificate issued by Authorised affairs of such Medical Authority person 7.6. Thus, we are fully satisfied that the assumption of jurisdiction by the Assessing Officer to pass the Assessment order is well within the provisions of law. Next Question that arise for our consideration is, can the assessment order is setaside with direction to pass fresh order in the name of legal heir, and if the same not time barred ?
7.7. We have answer for the same by the Jurisdictional High Court in the case of CIT -Vs- Sumantbhai C. Munshaw (decd.) reported in [1981] 5 Taxman 27 (Guj.) wherein it was held as follows: ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 12 “1. The determination of the question whether the AAC, in the instant case, was justified in directing afresh assessment would depend on the scope and effect of the provisions of section 159 and also on ascertaining the concepts of nullity, illegality and irregularity as understood in law. The real question that needs to be determined was whether in view of the facts and circumstances of the instant case, the fresh assessment proceedings ordered against the deceased was a nullity or mere illegality and irregularity. A nullity results from an error which is incurable and, therefore, fatal to the proceeding. An illegality occurs when there is a breach of some provision of law and an irregularity, which is usually amendable, occurs when some error of procedure is committed in the course of a proceeding. If there is a contravention of a directory provision, such act is not a nullity; if, however, a mandatory provision is contravened, it is a nullity. The safest rule to determine what is an irregularity and what is a nullity is to see whether the concerned party can waive the objection; if he can waive it, it amounts to an irregularity; if he cannot, it is a nullity. The underlying principle about waiver is that everyone has a right to waive and to agree to waive the advantage of a law or rule made solely for the benefit and protection of the individual in his private capacity, which may be dispensed with without infringing any public right or public policy.
2. A decree against a dead person is not a nullity for all purposes. If at the date of the death of the deceased assessee, a return in respect of the income earned by him in the previous year had already been filed and the assessment proceeding had commenced, it would not be necessary to start the proceeding afresh, against the legal representative, since any proceeding taken against the deceased prior to the date of his death is, by a fiction, deemed as having been taken against the legal representative. It would be necessary, therefore, to determine who the legal representative is and take all further steps in the proceeding against him. The legal representative will also be given full opportunity of being heard before an assessment is made on him in respect of the estate of the deceased. ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 13 3. Section 159, which merely prescribes the method for making assessment of tax in a special case, does not bear upon the initial jurisdiction of the taxing authority but deals with matters incidental to it. If the assessing authority, in the exercise of his jurisdiction, omits to take one or more of the various procedural steps therein laid down or in taking any or such steps commits an error or even deviates from the statutory mandate, the assessment would be null and void only if the omission, error or breach, as the case may be, is so fundamental as could not be waived because it affects inherent jurisdiction. If, however, the legal representative (which term includes plurality of persons) is present before the taxing authority in some capacity or voluntarily appears in the proceeding without service of notice or, upon service of notice not addressed to him but to the deceased assessee, does not object to the continuance of the proceeding against the deceased person and is heard by the ITO in regard to the tax liability of the deceased and invites an assessment on merits, such a legal representative must be taken to have exercised the option of abandoning the technical plea that the proceeding had not been continued against him, although, in substance and reality, it had been so continued. If and when an assessment order is consequently made in such proceeding in the name of the deceased assessee, even that would not be a nullity qua the legal representative, not only because he was afforded a full opportunity of being heard in respect of it but also because he, having not raised an objection at the appropriate time with regard to the continuance of the assessment proceeding against the deceased-person, must be taken to have known the inevitable outcome of the assessment being in the name of the deceased and to have opted to treat such an assessment as having been made as the legal representative against him and to have waived any objection as to its nullity on the said ground. Such an exercise of option on his part is not against public policy or public morality because the waiver is of a statutory provision which is conceived not in public interest but in the interest of the legal representative. It is obvious, therefore, that under such circumstances, the contravention of the relevant statutory provision would be a mere irregularity - maybe a gross irregularity - but not a nullity.
An error or omission in taking one or more of the various procedural steps prescribed under section 159 or even a breach of the statutory injunction contained therein does not necessarily affect the inherent jurisdiction of the taxing authority and in certain cases, ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 14 subject to other just exception open under the Act, the resultant defective assessment can be substituted by a fresh assessment undertaken pursuant to a finding or direction of a higher authority without any inhibition of time limit and, in others, the assessment would still be valid and effective, notwithstanding the. defect, depending upon the conduct of the parties and other relevant circumstances.
In the instant case, the Tribunal failed to find the basic and material facts and to examine and consider the aspect of "nullity" in its true and proper perspective on the basis of the facts found in the light of the rival submissions of both sides. The Tribunal failed to perceive the distinction between a nullity and irregularity and it also failed to take into account the aspect of waiver. Hence, the question referred to it was not answered by the Court and it was left to the Tribunal to reconsider its decision under section 260(1) in the light of the observations.
7.8. Respectfully following the above judicial precedents we hereby setaside the orders passed by the lower authorities and restore the issue to the file of the Jurisdictional Assessing Officer with direction to pass fresh assessment in the name the legal heir of the deceased assessee by giving proper opportunities of hearing to the legal heir and in accordance with the provisions of law. Thus the Grounds of Appeal raised by the Revenue are allowed.
In the result the appeal filed by the Revenue is allowed for statistical purpose.
Order pronounced in the open Court on 24.07.2025 at Ahmedabad. (MAKARAND V. MAHADEOKAR) (T.R. SENTHIL KUMAR) ACCOUNTNAT MEMBER JUDICIAL MEMBER Ahmedabad, Dated 24/07/2025 ITO Vs. Haresh Dayashankar Shrivastav AY : 2017-18 15 *Bt