High Court of Madhya Pradesh · Procedural orders and remands
Deputy Commissioner of Income Tax-I(I), Bhopal v. V.K. Brahmankar
Review Petition No. 619/2020 ·
Revenue review petition dismissed as abated after failure to act following the assessee’s death.
1. FACTS OF THE CASE
In Review Petition 619/2020, Revenue was informed that respondent V. K. Brahmankar had died more than two years earlier. Time had been granted to the petitioner to take the necessary steps.
2. DISCUSSION BY THE COURT
The Court recorded that the petitioner had still not taken the required action and found no ground to proceed further. It did not examine the grounds of review or the underlying assessment dispute.
3. JUDICIAL DECISION
Review Petition 619/2020 was dismissed as abated against the respondent assessee. The pending interlocutory application was also disposed of.
4. OUTCOME
Revenue’s review proceeding ended on abatement. The order specifies neither a tax issue nor an assessment year and does not pronounce on the correctness of the earlier substantive decision.
5. Expert Comments
AKHB editorial analysis, distinct from the Court’s findings.
The failure to act is central
Death alone is not the full procedural history recorded here: the Court had allowed time and Revenue had not done the needful. Case management must track the death report, the directions issued and the action actually taken before representing that review can proceed.
Source: PDF p.1, first two paragraphs
Abatement is not rejection on tax merits
The Court declined to proceed because the required action remained undone, not because it evaluated the proposed review grounds. The order cannot support a substantive proposition about the assessment or tax treatment that had led to the review.
Source: PDF p.1, complete order
Do not infer an unrecorded restoration remedy
No liberty to revive, substitution timetable or ruling on the liability of legal representatives appears in this order. Any later procedural remedy requires its own legal and factual foundation; this decision establishes only the recorded dismissal and disposal of the pending application.
Source: PDF p.1, operative paragraphs
Source and verification
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Original PDF: 2 pages · SHA-256: dcbabe73fa0a6d9452a606de8ce53ba3d7a8b0aef95f88399ecf655e48c47310
Full original and all five panels re-reviewed on 21 October 2026.
Current law and subsequent treatment not independently verified.
Subsequent proceedings and current judicial treatment have not been independently verified.
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