Following Mr. Gupta's death, his legal representatives did not file his income tax return for the Assessment Year (AY) 2020-21. On February 15, 2024, a notice under Section 148-A(b) was issued in Mr. Gupta's name, requesting him to explain why a formal notice under Section 148 should not be issued. This notice was delivered to the petitioner's address, prompting her to respond on February 26, 2024, where she communicated her husband's death and highlighted that his salary income of ?47,43,930 had already been subject to Tax Deducted at Source (TDS).

Despite this notification, the revenue department proceeded to issue a notice under Section 148 on March 21, 2024, leading the petitioner to challenge the validity of these proceedings.

The petitioner’s counsel argued that the notices issued to a deceased individual were void ab initio, meaning they lacked any legal effect from the outset. The importance of issuing such notices to the correct individual was emphasized by citing previous court rulings. The High Court's decision in Savita Kapila v. Assistant Commissioner of Income Tax underscored that a valid notice under Section 148 is crucial for the Assessing Officer's jurisdiction. If the notice is directed at a deceased person, the assessment proceedings lack legitimacy.

In response, the revenue department maintained that the notices complied with legal requirements, but this argument was met with skepticism given the clear precedent that addresses the necessity of notifying living individuals.

Judicial analysis from various rulings highlighted that tax notices issued posthumously cannot be sustained. In Chandresh Jayantibhai Patel v. ITO, the Gujarat High Court reiterated that a notice directed at a deceased individual undermines the jurisdictional authority necessary for assessment. Furthermore, the Court noted that there is no statutory requirement mandating legal representatives to inform tax authorities of a taxpayer's death.

The petitioner's case was bolstered by the established fact that TDS had already been deducted from Mr. Gupta's salary, negating any claims of escaped assessment. The legal framework stipulates that once tax is deducted at the source, the individual taxpayer cannot be held liable for further payments regarding that income.

Ultimately, the court ruled in favor of the petitioner, nullifying the notices issued under Section 148 and related provisions. This case underscores the critical need for tax authorities to adhere strictly to legal protocols, particularly when dealing with the estates of deceased individuals. It serves as a reminder of the protections afforded to legal heirs and the implications of administrative oversights in tax assessments. The decision emphasizes that tax authorities must navigate the complexities of inheritance law and ensure compliance with established judicial precedents to uphold the integrity of tax administration.