TMI Blog2023 (7) TMI 1506X X X X Extracts X X X X X X X X Extracts X X X X ..... xpressed by the Income Tax Officer in his order passed u/s 148A(d) that an attempt to suppress the details has been made by petitioner. The Income Tax Officer has accepted that the death of the deceased has been noted. Income Tax Officer also states in future the legal heir would be treated as deemed to be an assessee in respect of the deceased and the future notices would be issued in the name of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eir of one Anil Pragji Dhanani. The said Anil Pragji Dhanani (the deceased) expired on 2nd September 2016. The assessment of the deceased for AY-2013-2014 was reopened vide notice under the erstwhile provisions of Section 148 of the Income Tax Act 1961 (the Act) and the notice dated 28th June 2021 was issued. In response to the notice, a letter was addressed to the department on or about 27th July ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... served with a notice dated 29th October 2021 under Section 142(1) of the Act. Copy of the said notice is annexed to the petition but we do not see any response to the same. We would have expected petitioner to inform the department about his letter allegedly written on 27th July 2021 that the deceased had expired on 2nd September 2016. 3. Later, the deceased was served with a notice dated 24th Ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e communications there is no reference to the alleged letter dated 27th July 2021. Therefore, we would agree with the view expressed by the Income Tax Officer in his order passed under Section 148A(d) of the Act dated 30th July 2022 that an attempt to suppress the details has been made by petitioner. The Income Tax Officer has accepted that the death of the deceased has been noted. The Income Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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