The ld. AR in its written submission submitted that the issuance of valid notice is a foundation for the valid re-assessment proceedings. The notice prescribed u/s 148 is not a mere procedural requirement, but is a condition precedent to the validity of reassessment proceedings. If no notice is issued or if the notice issued is shown to be invalid, the proceedings initiated by the Assessing Officer would be invalid and void. In the instantcase, it was submitted that the proceedings u/s 147 were initiated against the deceased assessee who had expired on 10.10.2015 i.e. much prior to the issuance of notice u/s 148 on 31.03.2017. It was submitted that the impugned notice having been issued in the name of a deceased assessee was an invalid notice and consequently such reassessment proceedings are void ab initio. It was further submitted that such a notice could not have been served on the assessee as he had expired by that time and the notice has also not been served on the legal heirs which is a mandatory requirement under section 148(1) of the Act.