2023 (11) TMI 393

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..... es integra in light of CIT vs. Gowri [ 2019 (3) TMI 1165 - MADRAS HIGH COURT ] decided against the department, as upheld in [ 2019 (8) TMI 1883 - SC ORDER] hold in very clear terms that an assessee s legal representatives are not liable in penalty proceedings after his/her demise in terms of sec. 159 - We adopt the very reasoning herein as well to decline the Revenue s arguments support .....

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..... sec. 271(1)(c) penalty proceedings itself initiated after the assessee s demise. This is for the precise reason that the assessee Shri Jayant Maneklal Wagle had left for his heavenly abode on 19.11.2007 followed inter alia by the Assessing Officer s quantum assessment dated 30.12.2008; the CIT(A)'s first round lower appellate order dated 28.02.2014; sec. 271(1)(c) penalty order dated 30.03.201 .....

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