SHABINA ABRAHAM vs COLLECTOR OF CENTRAL EXCISE & CUSTOMS

The Supreme Court ruled that assessment proceedings under the Central Excises and Salt Act, 1944, cannot continue against the legal representatives of a deceased sole proprietor, as the Act lacks necessary provisions for such continuation. The Court emphasized that the definition of 'assessee' under the Act refers specifically to a living person liable for excise duty, thus holding that the proceedings abated upon the proprietor's death. The judgment affirmed the High Court's decision to quash the proceedings against the legal heirs, reinforcing the principle that tax liabilities cannot be imposed posthumously without explicit statutory provisions.