The Petitioner challenged the action of the respondents against Mr. Gene Gracious, the deceased husband of the petitioner, by issuance of reassessment notice. Mr. Gene Gracious against whom these notices were issued, expired. The notice issued under Section 148 preceded by earlier actions is required to be held to be non-est and void ab initio. The department cannot maintain issuance of the notice as impugned to a dead person. Even the legal heirs cannot be bound by such order which is non-est, void ab initio. [WP(L) 3460 of  2024, Dated 10/12/2024)