Section 148 of the Income-tax Act, 1961—Income escaping assessment—Notice under section 148 was not simply issued in the name of the dead person alone and on the other hand, it proceeds to indicate that the same was issued in the name of legal heirs including the petitioner, as the legal heirs, therefore, the notice issued under Section 148 in this case cannot be construed as if it was issued only in the name of the dead person, therefore, the petitioner can file return and seek for reasons for reopening and in that event it is the duty of the revenue to give reasons so as to enable the petitioner to file his objection to the reopening proceedings and once such objections are filed, a speaking order is to be passed by the revenue and when such course of action is yet to take place, the petitioner is entitled to maintain the writ petition by challenging the notice issued under Section 148 at the very initial stage- - S.M. SARVESWARAN (HUF) V/s ITO - [2019] 267 TAXMAN 542 (MAD)