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TMI Blog2021 (5) TMI 672X X X X Extracts X X X X X X X X Extracts X X X X ..... Junior Standing Counsel ORDER Heard Mr.K.Ravi, learned counsel for the petitioner and Mr.Prabu Mukunth Arunkumar, learned Junior Standing Counsel for the respondent. 2.The challenge is to an order of assessment dated 21.12.2019 passed under Section 144 read with Section 147 of Income Tax Act, 1961 (in short 'Act') for assessment year (AY) 2012-13. This writ petition has been filed by on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Y 2012-13. (iii) There was radio silence thereafter, and on 25.03.2019, a second notice under Section 148 of the Act was issued for the same assessment year, again addressed to K.Mangalam. (iv) On 20.06.2019 the Assessing authority addresses a reminder to K.Mangalam calling for a return in response to the notice under Section 148. (v) The factum of the demise of K.Mangalam was once again bro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Assessing authorities. (ix) In any event and without prejudice to the contention that the notice has been issued to a dead person, the Assessing Officer was alerted to the fact that K.Mangalam had left behind six legal representatives and hence notices, as legal representatives, should be issued to all of them and not just to the petitioner herein. No acknowledgment is placed for having fil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be preceded by notices that are issued to the assessee in question. No doubt, notice issued under Section 148 on 31.03.2017 is valid. However, for reasons best known to the Assessing Officer, this notice has not culminated in an order of assessment and has been allowed to lapse. The second notice dated 20.06.2019 has been again issued to K.Mangalam, despite the Assessing officer having been intima ..... X X X X Extracts X X X X X X X X Extracts X X X X
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