“Section 159(2)(a)(b)”

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.

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.

A notice for reassessment issued in the name of a deceased person is void ab initio and cannot be validated by curative provisions like Section 292B or 292BB, as issuing notice to the correct person is a fundamental jurisdictional requirement.

An assessment order passed against a deceased person, even if initiated after death, is null and void and must be set aside, especially when the return was filed by the legal representative.

An assessment order is bad in law if a notice under section 143(2) is not issued. However, if the assessee does not file a return within the time specified in a notice issued under section 148, and the return is treated as invalid, the Assessing Officer may not need to issue a notice under section 143(2).

An assessment notice issued under Section 148 to a deceased assessee without impleading their legal representative is invalid and the proceedings are void ab initio. The notice must be served on the legal representative as per Section 159(2)(b) of the Income Tax Act.

An active Permanent Account Number (PAN) for a non-existent entity, post-amalgamation, does not justify reassessment proceedings against that entity. The revenue cannot rely on an active PAN to dilute established legal principles regarding the assessment of merged entities.