(1.) We have heard Shri Sambhu Chopra, learned Counsel for the department. No one has entered appearance for the legal heirs of the Respondent.
(2.) Shri Naresh Chandra Bhargava -the Respondent in the reference died on 30.4.2002. A substitution application was filed on which notices were issued. Shri Ballabh Shukla, the Inspector in the office of Addl. Commissioner of Income Tax, Range -2, Allahabad has filed affidavit of service on 2.12.2003 enclosing there with notices, which were served by personal service upon the heirs of Shri Naresh Chandra Bhargava. The service was deemed to be sufficient on 3.9.2010.
(3.) On 7.9.2010 we passed the following order :