The first petitioner had filed reply to the show-cause notice under S. 148A issued in the name of his late father and was also heard. The notice under S. 148, which also was of the same date, i.e., 10th April, 2023, is in the names of late Naringaparambil Bhaskaran  and the first petitioner, who is the son/legal heir of late Naringaparambil Bhaskaran.  The petitioner filed the petition on the ground that the notice was in the name of deceased hence the order is bad in law. Dismissing the petition the Court held that  the petitioners cannot take a stand that since the show-cause notice under S. 148A(b) was not in their names, subsequent orders and notice under ss. 148A(b) and 148, respectively, cannot be passed and issued to them. Since the first petitioner had already participated in the proceedings by not only filing reply to the show-cause notice but also having been heard, this submission does not lie in the mouth of the petitioners and therefore, the same is liable to be rejected. The petitioners were not only aware of the proceedings, but also had participated in the proceedings. Therefore, the  contention is rejected. The order dt. 10th April, 2023, passed s. 148A(d) would disclose that after considering the reply and submissions of the first petitioner, the AO is of the opinion that the assessment for the year 2019-20 is required to be reopened under S. 147 by issuing notice under S. 148 and that the proceedings under S 148 would continue in the hands of the legal heirs of the assessee. The petitioners are granted 30 days further time from today to file return in pursuance to the notice under S.  148. (AY. 2019-20)