The High Court held that where a show-cause notice under Section 148A(b), an order under Section 148A(d), and a consequential notice for reassessment under Section 148 were all issued in the name of an assessee who had already expired, the entire action was non-est and void ab initio. The Court observed that the legislative scheme of Section 148A rests on the foundation of providing a hearing to the assessee, a mandatory requirement which cannot possibly be fulfilled in the case of a dead person. As the foundational procedure was itself a nullity, the entire superstructure of reassessment proceedings collapses. Such void proceedings cannot bind the legal heirs of the deceased. The Court, while quashing the notices and order, clarified that the Revenue was at liberty to initiate fresh proceedings against the legal heirs, subject to the requirements of law, including limitation. (AY. 2015-16)