Shabina Abraham & Ors vs Collector Of Central Excise & Customs

The Supreme Court held that the Central Excises and Salt Act, 1944 lacks provisions for continuing assessment proceedings against a deceased individual’s estate. The Court emphasized that the definition of 'assessee' under the Act refers specifically to a living person liable for excise duty, and without explicit statutory machinery, proceedings cannot be sustained post-mortem. Consequently, the Court upheld the High Court's decision to quash the proceedings against the legal heirs, affirming that the assessment proceedings abated upon the death of the sole proprietor.