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“legal representative”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(29)662 judgments

The decision most relied on for legal representative is 2 CIT v. Indrajit Singh Suri (33 Taxmann.com 281), cited in 100 judgments on BharatTax.

Leading authorities on legal representative

2 CIT v. Indrajit Singh Suri
33 Taxmann.com 281 · 2013 · High Court
100
citing judgments

The validity of reassessment proceedings initiated under Sections 147/148 against legal representatives of a deceased assessee requires a demonstrable 'reason to believe' that income escaped assessment, often based on third-party information such as alleged accommodation entries.

Savita Kapila v. ACIT
118 Taxmann.com 46 · 2020 · High Court
98
citing judgments

There is no legal requirement for a legal representative to report an assessee's death to the income tax department; consequently, a reassessment notice issued under Section 148 to a deceased person is invalid as it lacks proper jurisdiction.

Chandreshbhai Jayantibhai Patel v. ITO
101 Taxmann.com 362 · 2019 · High Court
46
citing judgments

A notice under section 148 of the Income-tax Act, 1961, is a jurisdictional notice and a condition precedent for reassessment. Such a notice issued against a deceased person is valid if the legal representative submits to the Assessing Officer without raising any objection.

CIT v. Amarchand N. Shroff
48 ITR 59 · 1963 · Supreme Court
40
citing judgments

Assessment proceedings initiated against a deceased person are void. Once an assessee dies, assessment proceedings can only continue in the name of their legal representative, to the extent of the deceased's estate.

202 ITR 932, CIT v. Durgawati
31 ITR 603 · 1957 · High Court
36
citing judgments

The same income cannot be assessed substantively in multiple hands. However, this principle does not prevent a single consolidated assessment order for multiple legal representatives.

CIT v. Jai Prakash Singh
219 ITR 737 · 1996 · Supreme Court
36
citing judgments

A procedural defect in serving notices, such as issuing them after the assessee's death without proper service on legal representatives, can invalidate reassessment proceedings and render assessment orders void. However, an omission or defect in serving notices does not erase a tax liability created by substantive provisions, though it may render an order irregular.

Rajender Kumar Sehgal v. ITO
260 Taxmann 412 · 2019 · High Court
25
citing judgments

A notice issued to a deceased assessee or their legal representatives beyond the period of limitation is without jurisdiction and cannot be saved by Section 292B.

ITO Ward 1(3)(7), Surat v. Durlabhbhai Kanubhai Rajpara
114 Taxmann.com 482 · 2020 · Supreme Court
24
citing judgments

An assessment or reassessment proceeding initiated or continued against a deceased person after their demise is illegal and void ab initio, as no valid notice can be issued to a dead individual.

Judgments citing legal representative

Mr Colathur N. Ram, Mumbai vs. Assistant Commissioner of Income Tax 34(1), Mumbai

In the result, the appeal is partly allowed for statistical purposes in terms of what we have observed hereinabove

ITA 1464/MUM/2024[2013-14]Status: DisposedITAT Mumbai17 Sept 2024AY 2013-14

Bench: SHRI BR BASKARAN (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

Section 143(1)Section 143(2)Section 250Section 54

mentioned above. 14. The strong reliance was placed on the following decisions by the appellant. In Late Mir Gulam Ali Khan (By legal representative Mrs. Noor Begum) ..vs.. Commissioner of Income Tax; 228 Income Tax Reports 165 (A.P.) the Andhra Pradesh High Court has granted exemption under section ... house, entered into an agreement for purchasing another house and paid a sum of Rs. 1,000 as earnest money and subsequently the legal representative completed the transaction within a period of one year from the date of the death of the deceased. The sale and purchase are two links

Manohars Catering, Bengaluru vs. Income Tax Officer, Ward-7(2)(3), Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1393/BANG/2024[2008-09]Status: DisposedITAT Bangalore13 Sept 2024AY 2008-09

Bench: Mrs. Beena Pillai & Shri Ramit Kocharassessment Year: 2008-09 Manohars Catering, Assistant Commissioner Of Income-Tax & / Or The Partners/ Circle-1, Bangalore Legal Representatives Of (Present Jurisdiction-Income Tax The Partners Of Manohars Officer-Ward7(2)(3), Bangalore) Catering As Stipulated U/S V. 189(1), 189(3) & 189(4) Of The 1961 Act Number 666, Indiranagar 1St Stage Bengaluru-560038 Karnataka Pan:Aalfm1212B (Appellant) (Respondent) Assessee By: Sh. Raghvendra, Ca Revenue By: Ms. Neha Sahay, Jcit Dr Date Of Hearing: 05.09.2024 Date Of Pronouncement: 13.09.2024 O R D E R

For Appellant: Sh. Raghvendra, CAFor Respondent: Ms. Neha Sahay, JCIT DR
Section 143(1)Section 143(2)Section 143(3)Section 194ISection 246A(1)(a)Section 250Section 37Section 40

SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER Assessment Year: 2008-09 Manohars Catering, Assistant Commissioner of Income-tax, and / or The Partners/ Circle-1, Bangalore Legal Representatives of (Present jurisdiction-Income Tax the Partners of Manohars Officer-Ward7(2)(3), Bangalore) Catering as Stipulated ... dissolved or business discontinued, every person who has at the time of such discontinuance or dissolution a partner of the firm, and the legal representative of any such person who is deceased , shall be jointly and severally liable for the amount of tax, penalty or other sum payable

Estate of Arjun Das Agarwal, Kolkata vs. ITO, Ward-40(3), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 373/KOL/2024[2012-13]Status: DisposedITAT Kolkata10 Sept 2024AY 2012-13

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.373/Kol/2024 Assessment Year: 2012-13 Estate Of Arjun Das Agarwal………………………… ........................……Appellant Flat No.3B, 19-B, Richie Road, Ballygunge, Kolkata – 700019. [Pan: Aabae1990M] Vs. Ito, Ward-40(3), Kolkata…...................…................…........……...…..…..Respondent Appearances By: Shri Ravi Tulsiyan, Ar, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 12, 2024 Date Of Pronouncing The Order : September 10, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By Estate Of Arjun Das Agarwal Through Sri Vivek Agarwal In A Representive Capacity, Against The Order Dated 31.01.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That Return Of Income For Assessment Year 2012-13 Was Filed By Sri Arjun Dass Agarwal During His Life Time On 31.03.2014 Declaring Total Income Of Rs.2,43,159/- & The Same Was Processed U/S 143(1) Of The Act On 26.07.2014. Shri Arjun Dass Agarwal Died On 11.12.2015. Thereafter, The Assessing Officer Received Some Information Regarding Transaction Of Immovable Property Done By Sri

Section 142(1)Section 143(1)Section 148Section 250

date, there was no legal heir determined of late Arjun Dass Agarwal. He accordingly held that the appellant was not the legal representative of Sri Arjun Dass Agarwal and dismissed the appeal as not maintainable. 4. Appeal against the said order has been filed before us, by Estate of Arjun ... this stage, it will be relevant to reproduce the relevant provisions of section 159 of the Act: “159. (1)Where a person dies, his legal representative shall be liable to pay any sum which the deceased would have been liable to pay if he had not died, in the like

Madan Lal Kochar (Through Sahil Kochar), New Delhi vs. Pr, CIT Delhi-12, Delhi

In the result, the appeal of the assessee is allowed

ITA 2516/DEL/2024[2016-17]Status: DisposedITAT Delhi05 Sept 2024AY 2016-17

Bench: Shri Kul Bharat[Assessment Year : 2016-17] Madan Lal Kochar (Through Sahil Vs Pr.Cit-12, Kochar), M/S. Satish Aggarwal & New Delhi. Associates, 4/5B, 1St Floor, Asaf Ali Road, New Delhi-110002. Pan-Acmpk7272L Appellant Respondent Appellant By Shri Satish Aggarwal, Ca Respondent By Shri Siddharth B.S.Meena, Sr.Dr Date Of Hearing 02.09.2024 Date Of Pronouncement 05.09.2024

Section 147Section 263

provisions of section 263, the PCIT is not empowered to pass an order under section 263 in the hands of the legal representative after the death of the assessee. It further held in Para 10 that following the decision of Gujrat High Court in the case of Bhupendra Bhikhalal Desai ... required to intimate to the department the fact of the demise of the assessee, the court held that no duty is cast upon a legal representative to intimate factum of death of the assessee to the department. 12) The court in above case went on to state that irrespective

ITO Non Corporate Ward 19 (4), Chennai vs. Shri. K Venkatakrishnan, Chennai

ITA 1537/CHNY/2018[2008-09]Status: DisposedITAT Chennai04 Sept 2024AY 2008-09

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1458/Chny/2018 िनधा"रण वष"/Assessment Year: 2008-09 V. Shri K. Venkatakrishnan, The Ito, Legal Heir Of Late – Ncw-20(2), Shri K.S.Deenadayalu Reddy, Chennai. No.3/1, Old No.2, Avalon Flats, Ground Floor, Sixth Street, Gopalapuram, Chennai-600 086. [Pan: Aakpv 7243 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 148Section 151

void ab initio, since the notice under section 148 as well as the assessment order were on the deceased assessee and not on the Legal Representative. The mere reference in the notice as addressed to the "dead assessee is represented by the legal heir" does not convert the notice having ... been issued to the legal representative. 3. The notice under section 148 also does not mention that the notice is issued to legal representative to assess / reassess the income in respect the dead assessee and the same shows that the notice is issued only to the dead assessee. The notice

K.Venkatakrishnan, Legal Heir of Late Shri K.S.Deenadayalu Reddy, Chennai vs. ITO Non Corporate Ward 20(2), Chennai

ITA 1458/CHNY/2018[2008-09]Status: DisposedITAT Chennai04 Sept 2024AY 2008-09

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1458/Chny/2018 िनधा"रण वष"/Assessment Year: 2008-09 V. Shri K. Venkatakrishnan, The Ito, Legal Heir Of Late – Ncw-20(2), Shri K.S.Deenadayalu Reddy, Chennai. No.3/1, Old No.2, Avalon Flats, Ground Floor, Sixth Street, Gopalapuram, Chennai-600 086. [Pan: Aakpv 7243 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri A. Sasikumar, CIT
Section 148Section 151

void ab initio, since the notice under section 148 as well as the assessment order were on the deceased assessee and not on the Legal Representative. The mere reference in the notice as addressed to the "dead assessee is represented by the legal heir" does not convert the notice having ... been issued to the legal representative. 3. The notice under section 148 also does not mention that the notice is issued to legal representative to assess / reassess the income in respect the dead assessee and the same shows that the notice is issued only to the dead assessee. The notice

Real Cargo Mumbai, Arvalli vs. The ITO, Ward-1, Modasa

In the result, the appeal of the assessee in ITA No

ITA 268/AHD/2024[2010-11]Status: DisposedITAT Ahmedabad30 Aug 2024AY 2010-11

Bench: Income-Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad. This Appeal In Ita No.268/Ahd/2024 For Assessment Year 2010-11, Is Filed By The Assessee Before Income Tax Appellate Tribunal, Ahmedabad Division Bench, Ahmedabad Has Arisen From The Appellate Order Dated 25.09.2023 Passed By Ld. Commissioner Of Income-Tax(Appeals), Nfac, Delhi U/S. 250 Of The Income- Tax Act,1961 , Vide Din & Order No. Itba/Nfac/S/250/2023- 24/1056508501(1), Which Has In Turn Arisen From The Assessment Order Dated 18.12.2018 Passed By The Assessing Officer U/S. 143(3) Read With Section 254 Of The Income-Tax Act 1961. 2. The Grounds Of Appeal Raised By The Assessee In Memo Of Appeal Filed With The Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad , Reads As Under:-

For Appellant: Shri S.N.Divatia ,Advocate & ShriFor Respondent: Shri Akhilendra Pratap Yadav,CIT-DR
Section 143(3)Section 189(1)Section 250Section 253(3)Section 254Section 40

Ramit Kochar, Accountant Member & Shri T.R.Senthil Kumar, Judicial Member Assessment Year: 2010-11 Real Cargo Mumbai The Income Tax and / or The Partners/ Officer, Legal Representatives v. Ward-1, Modasa, of the Partners of Real Aayakar Bhawan Cargo Movers as Modasa, Stipulated u/s 189(1), District Aravalli ... dissolved or business discontinued, every person who has at the time of such discontinuance or dissolution a partner of the firm, and the legal representative of any such person who is 10 I.T.A No.268/Ahd/2024 A.Y. 2010-11 Page No. Real Cargo Mumbai deceased , shall be jointly and severally liable

Rahul Gupta, Shahjahanpur vs. Income Tax Officer 3(2), Hardoi

In the result, both appeals of the assessee are partly allowed

ITA 123/LKW/2023[2017-18]Status: DisposedITAT Lucknow29 Aug 2024AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Shri Sanjay Saxena, CAFor Respondent: Shri. Sanjeev Krishna Sharma, Addl
Section 271ASection 271BSection 273B

father, was filed along with a copy of legal heir certificate issued by the District Authorities, Hardoi wherein the assessee’s name appears as legal representative of late Shri Sushil Kumar Gupta. The Ld. AR submitted that one more opportunity should be granted to the assessee in order to represent

Rahul Gupta, Shahjahanpur vs. Income Tax Officer 3(2), Hardoi

In the result, both appeals of the assessee are partly allowed

ITA 122/LKW/2023[2017-18]Status: DisposedITAT Lucknow29 Aug 2024AY 2017-18

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: Shri Sanjay Saxena, CAFor Respondent: Shri. Sanjeev Krishna Sharma, Addl
Section 271ASection 271BSection 273B

father, was filed along with a copy of legal heir certificate issued by the District Authorities, Hardoi wherein the assessee’s name appears as legal representative of late Shri Sushil Kumar Gupta. The Ld. AR submitted that one more opportunity should be granted to the assessee in order to represent

P S Metal Store, New Delhi vs. ITO Ward- 63(3), New Delhi

In the result, appeal of the assessee is allowed in the aforesaid manner

ITA 851/DEL/2020[2007-08]Status: DisposedITAT Delhi29 Aug 2024AY 2007-08

Bench: Shri Shamim Yahya & Shri Narinder Kumara.Yr. : 2007-08 P S Metal Store, Ito Ward 63(3), 5837, Basti Harphool Singh, Vs. New Delhi – 110 002 Sadar Bazar, Delhi – 110 006 (Pan: Adbpj5099C) (Appellant) (Respondent)

For Appellant: : Shri Ved Jain, Adv. &For Respondent: Shri Yogeshwar Sharma, Sr. DR
Section 142(3)Section 147Section 148Section 69C

accordingly, issued notice u/s. 148 of the Act on 14.3.2014. In response to the 3 notice, the AR of the legal representative of the assesse filed reply dated 16.5.2014 stating that the above assessee had already expired, therefore there was no effective service of the notice

K H Gurunath Lr of Late K L Srihari, Bangalore vs. DCIT Central Circle 1(1), Bangalore

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 1268/BANG/2024[2010-11]Status: DisposedITAT Bangalore27 Aug 2024AY 2010-11

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2010-11

For Appellant: Shri V. Sridhar, CAFor Respondent: Shri Srinivasa Karthik Devara
Section 142(1)Section 147Section 148Section 246

constructed area. The assessee earned capital gain, therefore the AO issued notice u/s. 148 of the Act on 30.3.2017 duly served on the LR( Legal Representative) of the assessee after recording reasons, which is incorporated in reassessment order. The LR filed objections for reopening the assessment. Later on a notice

Late Keshav Pandurang Gadre Th. L/H Manish Gadre (Son), Bhopal vs. ITO-2(4), Bhopal

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 370/IND/2024[2011-12]Status: DisposedITAT Indore23 Aug 2024AY 2011-12

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanilate Keshav Pandurang Gadre Ito 2(4) 67 Maa Nilay Ansal Pradhan Bhopal Enclave Near Dana Pani Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Abgpg1037Q Assessee By None Shri K. Bala Murali Krishna, Sr. Dr Revenue By Date Of Hearing 22.08.2024 Date Of Pronouncement 23.08.2024

Section 147Section 148

when this appeal was called for hearing. At the outset, we note that this appeal has been filed by son of the assessee as legal representative of the deceased assessee who expired on 12th April 2015 as per the copy ITANo.370/Ind/2024 Late Keshav Pandurang Dadre of the death certificate filed ... assessee after reopening of the assessment vide Page 2 of 4 ITANo.370/Ind/2024 Late Keshav Pandurang Dadre notices u/s 148 dated 24.03.2018. Further the legal representative of the assessee has explained that since the case was migrated to National Faceless Appeal Centre, the notice issued by the CIT(A) were

Jairaj Singh Solanki, Jaipur vs. ITO Ward 2(4), Jaipur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 896/JPR/2024[2017-18]Status: DisposedITAT Jaipur20 Aug 2024AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Shrawan Kumar Gupta (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 115Section 115BSection 142(1)Section 143(2)Section 144Section 234Section 69A

sufficient cause liberally either because the party in default is the Government or because the question arises in connection with the impleading of the legal representatives of the deceased respondent. The provisions of the Code are with a view to advance the cause of justice by applying the principle

Smt. Pashiben Prajapati Family Trust (Disc), Ahmedabad vs. The Income Tax Officer, Ward-3(3)(5), Ahmedabad

The appeal of the assessee is partly allowed in the manner as indicated above

ITA 305/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad16 Aug 2024AY 2021-22

Bench: Ld. Cit(A) Has In-Turn Arisen From The Intimation Dated 07.12.2022 Issued By Cpc, Bengaluru, U/S.154(Cpc/2122/U5/ 314311772) Of The Act.

For Appellant: Shri Rupesh R Shah, AdvocateFor Respondent: Shri Sanjay Jain, Sr. D.R
Section 154Section 164(1)Section 250Section 80Section 80C

before the vesting day, by an unanimous decision in writing after transferring the assets, of the Trust Fund to the beneficiaries (or to their legal representative) according to their absolute discretion. It is observed by me that the aforesaid WILL is not happily worded , and there are many mistakes while

Deputy Commissioner of Income Tax, Central Circel-2(1), Nagpur vs. Shri Ramakant Govindrao Mendhe, Nagpur

In the result, appeal filed by the Revenue for the A

ITA 163/NAG/2023[2019-20]Status: DisposedITAT Nagpur08 Aug 2024AY 2019-20

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 133ASection 142(1)Section 144Section 147Section 148Section 69ASection 69C

respectively. I have carefully perused the assessment order of the AO and the submission made by the appellant. The legal representative of the assessee is a house wife. She does not know anything about the transaction made by the appellant, as the appellant was not discussing the business transactions with

Deputy Commissioner of Income Tax, Central Circle-2(1), Nagpur vs. Shri Ramakant Govindrao Mendhe, Nagpur

In the result, appeal filed by the Revenue for the A

ITA 162/NAG/2023[2018-19]Status: DisposedITAT Nagpur08 Aug 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: NoneFor Respondent: Shri Abhay Y. Marathe
Section 133ASection 142(1)Section 144Section 147Section 148Section 69ASection 69C

respectively. I have carefully perused the assessment order of the AO and the submission made by the appellant. The legal representative of the assessee is a house wife. She does not know anything about the transaction made by the appellant, as the appellant was not discussing the business transactions with

Gopaliyengar Madabushi Muralidhar, Bengaluru vs. Income-Tax Officer, Ward-7(2)(4), Bengaluru

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 956/BANG/2023[2016-17]Status: DisposedITAT Bangalore08 Aug 2024AY 2016-17

Bench: Shri Chandra Poojari (Accountant Member), Shri Keshav Dubey (Judicial Member)

For Appellant: Shri Hemant Pai, CAFor Respondent: Shri V. Parithivel, JCIT-DR
Section 143(2)Section 143(3)Section 144Section 234BSection 250Section 271(1)(c)Section 68

dated 13.12.2018 was issued only to the assessee in the name of Shri G.M. Muralidhar and not in the name of the legal representative as alleged by the Ld. AR of the Assessee. Further, the learned D.R. fervently submitted that in 7 Gopaliyengar Madabushi Muralidhar the notice ... aforesaid provision expressly provides that the death of the party is of no consequence and the proceeding under the act can proceed against the legal representatives of the assessee and the proceedings initiated against the deceased assessee shall be deemed to be the proceeding initiated against legal representatives

A Bliss of Creator Society, Jaipur vs. Exemption Ward 1, Jaipur

ITA 608/JPR/2023[2012-13]Status: DisposedITAT Jaipur06 Aug 2024AY 2012-13
For Appellant: Shri R.S. Poonia, CA &For Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 11Section 13Section 143

sufficient cause' liberally either because the party in default is the Government or because the question arises in connection with the impleading of the legal representatives of the deceased respondent. The provisions of the Code are with a view to advance the cause of justice by applying the principle

Smt. Bridget Anthony(Legal Heir of Late Mr. Elevathingal Joseph Anthony), Bangalore vs. Income-Tax Officer, Ward-4(2)(1), Bangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 509/BANG/2024[2015-16]Status: DisposedITAT Bangalore05 Aug 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Shri V. Parithivel, D.R
Section 143(2)Section 250Section 69

fresh facts otherwise on record and the action of the assessee is bonafide. 4. Facts of the case are that the appellant is the legal representative of Late Sri. Elavanthingal Joseph Anthony (“Late E J Anthony”, for short). Mr. E J Anthony had filed his return of income ... cash on various dates 4.3 Mr. Anthony died on 07.10.2016. After his death, the present appellant Smt. Bridget Anthony was brought on record as legal representative. The learned Assessing Officer, in order to verify the correctness of the declared sale consideration of Rs. 2,00,00,000/- summoned. Mr. Parasmal

Gulab Bai, Kota vs. ITO, Income Tax

In the result, the appeal of the assessee is dismissed with no orders as to

ITA 320/JPR/2024[2012-13]Status: DisposedITAT Jaipur02 Aug 2024AY 2012-13
For Appellant: Shri Harish K. Tripathi, AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 249(2)Section 249(3)Section 54B

sufficient cause’ liberally either because the party in default is the Government or because the question arises in connection with the impleading of the legal representatives of the deceased respondent. The provisions of the Code are with a view to advance the cause of justice by applying the principle