ALLAHABAD HIGH COURT · SOURCE-REVIEWED INTERIM ORDER
Principal Commissioner of Income Tax-1 v. M/s Shivam Dairy Farm
INCOME TAX APPEAL No. 123 of 2025 ·
Supplied court order; reported citation not indexed
The appeal was admitted; notice was issued, steps were due within one week, paper books within eight weeks, and hearing in due course.
Division Bench · Saumitra Dayal Singh · Swarupama Chaturvedi
1. Facts of the case
The appeal concerned the validity of a Section 263 order involving a deceased proprietor’s legal representative.
2. Discussion by the Hon’ble Court
Two admitted questions addressed the inclusive definitions in Section 2(29) of the Act and Section 2(11) CPC, and whether responding to notices and queries constituted intermeddling with the estate. These were issues for decision.
3. Judicial decision
The appeal was admitted; notice was issued, steps were due within one week, paper books within eight weeks, and hearing in due course.
4. Outcome / in whose favour
The legal-representative issues were admitted, not answered.
5. Expert Comments
AKHB editorial analysis, distinct from the Court’s findings. Subsequent treatment and current-law applicability have not been verified.
The admitted questions are not findings against the legal heir
The questions ask whether the inclusive legal-representative definitions and alleged responses to notices undermine invalidation of the section 263 order. They do not decide that this person intermeddled with the estate or was validly brought on record. Those propositions remain matters for hearing.
Source: PDF p.1 · PDF 1
Separate status, conduct and validity in preparing the record
The two questions link identification of the deceased proprietor’s representative with the heir’s alleged dealings with notices and assets. A useful paper book would distinguish evidence of that conduct from the legal consequences claimed for revision. The order sets one week for notice steps and eight weeks for paper books; it supplies no merits answer.
Source: PDF p.1 · PDF 1
Source and verification
Complete supplied 1-page original read and every page visually inspected; original PDF bytes verified by SHA-256 against the review ledger. Only source-identified provisions and assessment years are indexed. No PAN is stated. No current-law clearance is claimed.
Source SHA-256: 96e1c87ab41e901b0b5197867c6ec4e25196492899ec26bdb31bb344bc3acc86
Only source-identified provisions are recorded. No current monetary threshold, current statutory equivalence or 2025 Act applicability is inferred.
Source checked 2026-10-21. Subsequent proceedings and current precedential treatment have not been comprehensively verified.
AI disclosure and professional disclaimer
This AKHB research note was prepared with AI assistance from an identified primary report. Independent human review is not represented.
General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. The AKHB Expert Comments is editorial analysis, not the Court’s holding. No current-law clearance is claimed.