Held, allowing the petition, that the mandatory requirement of prior show-cause notice, hearing and passing of order under section 148A before issuance of reassessment notice under section 148 could not be fulfilled in the case of a dead person. The legal heirs could not be bound by a non-existent order. However, the Department was not precluded from issuing fresh notice again heirs if the requirements of section 147 or 148 were otherwise satisfied. Followed  UMC Technologies Pvt. Ltd. v. Food Corporation of India, (2021) 2 SCC 551; 2020 SCC OnLine SC 934, wherein the Court held that be the first principle of civilised jurisprudence that a person against whom any action is sought to be taken or whose right or interests are being affected should be given a reasonable opportunity to defend himself.  (AY. 2015-16)