Assessing Officer issued a reopening notice in name of Smt . Bhatiben Harendra Modi on ground that on basis of information in Annual Information Return (AIR), it was found that said deceased assessee had sold one immovable property amounting to Rs. 82.89 lakhs but did not file any income tax return, thus, income to said extent had escaped assessment due to failure of  Smt .Bhatiben Harendra Modi to submit her return of income  Petitioner being heir and legal representative of Smt .Bhatiben Harendra Modi  contended that  Bhatiben Harendra Modi had already expired and, therefore, impugned notice in name of Smt . Bhatiben Harendra Modi  was not valid . High Court  held that notice issued under section 148 against  Smt .  Bhatiben Harendra Modi  was to be quashed and set aside.  (AY 2012-13)