IN THE INCOME TAX APPELLATE TRIBUNAL Mumbai “G” Bench, Mumbai.

Before Shri Rahul Chaudhary (JM) & Shri Omkareshwar Chidara (AM)

ITA No. 3170/MUM/2025 (Assessment Year : 2011-12) ITA No. 3171/MUM/2025 (Assessment Year : 2012-13)

ITO-22(3)(1) Yakub Mohamed Ghantiwala Room No. 307, 3rd Floor Through Legal Heir of Late Piramal Chambers Vs. Yakub Mohamed Ghantiwala Lalbaug, Parel Bibi Yakub Mohamed Ghan Mumbai-400 012. Flat No. 303, 3rd Floor Building Name Reyhaan-2 Plot Bearing No. CTS No. 74/A,B Village Bandiwali Jogeshwari West Mumbai-400 0102. PAN : AABPG8470D Appellant Respondent Assessee by : Shri Mohammad Shahab Khan Revenue by : Shri Swapnil Choudhary Date of Hearing : 26 /06/2025 Date of pronouncement : 26/08/2025 O R D E R Per Omkareshwar Chidara (AM) :-

For the assessment year 2011-12 and 2012-13, the Revenue raised the following grounds of appeal :-

1 . Whether on the facts and in circumstances of the case and in law Ld. CIT(A) erred in quashing the assessment order parsed under section 144 r.w.s. 147 of the Income-tax Act, 1961, on the sole ground that the notice under section 148 was issued in the name of a deceased person, despite the fact that the death of the assessee was ne