Tax Proceedings Against Deceased Sole Proprietor End with Death, Legal Heirs Cannot Face Demands Without Rule 22 Application

CESTAT held tax proceedings against a deceased sole proprietor cannot continue against legal heirs. Following SC precedent in Shabina Abraham, tax demands expire with proprietor's death. Legal heir lacked standing as no Rule 22 application was filed before proprietor's death to claim appeal rights. Appellant failed to provide evidence of succeeding father's business ownership. Death certificate confirmed proprietor's demise, rendering proceedings non-maintainable. Section 22 provisions for legal heir claims were not properly invoked within prescribed timeline. Appeal dismissed as proceedings cannot survive proprietor's death or transfer to heirs without proper succession documentation. .....

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