IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER AND SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER आयकर अपील स.ं /ITA No.1300/SRT/2024 Assessment Year: (2015-16)

(Hybrid Hearing)

Late Priyank Narendrabhai Patel, Vs. ITO, Through his L/h Narendrabhai Patel, Ward – 2, At & Post – Tundi, Tal – Palsana, Bardoli Surat - 394315 èथायीलेखासं./जीआइआरसं./PAN/GIR No: ASAPP4783F (Appellant) (Respondent) Appellant by Shri Hiren Vepari, CA Respondent by Shri Ajay Uke, Sr. DR Date of Hearing 10/09/2025 Date of Pronouncement 03/12/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM:

This appeal by the assessee emanates from the order passed under section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) dated 28.10.2024 by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [in short, ‘CIT(A)’] for the assessment year (AY) 2015-16.

2. The grounds of appeal raised by the assessee are as under:

“Validity:

(1) The proceedings having been undertaken in the name of dead person are not legally sustainable.

(2) The statutory notice u/s 143(2) that enables to carry out assessment issued on dead person no assessment could