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In favour of assessee.The purport of Section 292B of the Act is that in the event of any mistake, defect or omission in the notice or other proceedings, if the same is in conformity with or according to the intent and purpose of the Act, the notice cannot be termed as invalid.

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Section 292B of the Income Tax Act, 1961 — Reassessment — Notice — The provisions of section 292B are not applicable and framing of assessment against a non existing entity or person goes to the root of the matter which is not a procedural irregularity, but a jurisdictional defect. as there cannot be any assessment against a dead person and mere intimation by the legal representative that the notice is dead would not amount to participation in the reassessment proceedings — Urmilaben Anirudhhasinhji Jadeja vs. Income tax Officer [2020] 420 ITR 226 (Gujarat)

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