An appeal may be dismissed for non-compliance with court directions to implead legal heirs of a deceased assessee, provided the party is granted liberty to seek revival upon fulfilling the procedural requirements.

O R D E R

PER SANJAY AWASTHI, ACCOUNTANT MEMBER:

1. This is an appeal filed by the Assessee who is since deceased. It is observed that the appeal has been filed by an alleged legal heir of the assessee. This fact was duly noted vide order-sheet entry dated 17.04.2025 as under: -

Allowed. Legal heirs be impleaded. Amended Bench: C Form 36 be filed. Adjourned to 12.06.2025 17-Apri-2025 (Thursday). Both parties are informed in the (Thursday) Open Court.

Sd/- Sd/-

AVDHESH KUMAR MISHRA ANUBHAV SHARMA

(ACCOUNTANT MEMBER) (JUDICIAL MEMBER)

1.1 Thereafter, after several ineffective dates of hearing, the matter was listed before the present Bench on 06.05.2026.

2. The Ld. DR placed on record a report by ITO, Ward 49(1), Delhi as under: -

“Sir/Madam

Kindly refer to the captioned subject and the mail trail forwarded herewith.

As per directions, proceedings were initiated to take legal heir of the assessee on records, however, in absence of Death/Surviving member/legal heir Certificate the legal heir could not be added to the PAN of the assessee. In this regard, communications were made on the last known address/e-mail of the assessee and also through e-filing portal but no response has been received. Hence, revised Form 36 along with Grounds of appeal may not be uploaded online taking legal heir on record at this stage. This is for your kind information and directions please.”

3. Considering the lack of persuasion in the present matter by the assessee and also the fact that the directions of the Bench to bring the legal heirs on record has not been complied with, we feel constrained to dismiss the present appeal, with liberty to the assessee to seek revival of the same once the legal heirs have been brought on record.

4. In the result, appeal of the assessee is dismissed.