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Sec. 147 & 292BB of Income Tax Act, 1961— Re-assessment — Issuance of a notice under Section 148 is the foundation for reopening of an assessment, consequently, the sine qua non for acquiring jurisdiction to reopen an assessment is that such notice should be issued in the name of the correct person and this requirement of issuing notice to a correct person and not to a dead person is not merely a procedural requirement but is a condition precedent to the impugned notice being valid in law. - SAVITA KAPILA V/s ASSTT. CIT -  426 ITR 502 (DELHI)