1. Section 93(1) of the CGST Act covers tax, interest and penalty. The words "is determined after his death" permit determination and proceedings to be commenced after the death of the person liable. Issuing a notice during his lifetime is not a condition precedent.

2. The concluding words of Section 93(1) distinguish a liability determined before death but unpaid from one determined after death. The opening words "where a person, liable to pay tax, interest or penalty under this Act, dies" cannot be confined to a liability already quantified before death.

3. Investigation and adjudication are distinct stages. The power to proceed after death comes from Section 93 itself, not from the fact that investigation began or a statement was recorded during the deceased's lifetime. That material can still form part of the evidentiary record in the adjudication.

4. Section 93 is not an independent penal provision against the legal representative. The substantive penalty comes from the other provisions, such as Section 122(3)(a). The underlying liability must arise from conduct attributable to the deceased, and it must still be established in adjudication. Section 93 only enables that liability to be determined and enforced through the legal representative.

5. Under Section 93(1)(a), the legal representative or other person continuing the business is liable for the dues. Under Section 93(1)(b), where the business is discontinued, the legal representative is liable only out of the estate of the deceased, to the extent the estate can meet the charge.

6. Proceedings do not automatically abate on the death of the alleged wrongdoer. Shabina Abraham and Dr. K.C.G. Verghese do not lay down a rule independent of the statutory scheme. Section 93 supplies the machinery for determination after death, without recourse to the deeming provisions of the Income Tax Act.

7. A show cause notice is not without jurisdiction solely because it was issued after the death. Lapse of time after death does not by itself bar proceedings under Section 93, but applicable limitation requirements still apply.

8. Section 93(1)(b) does not violate Article 14. It does not deem the representative to have committed the wrong. Payment is confined to the estate, and the contravention and conditions of liability must still be established. The provision has a rational basis in preserving liabilities for satisfaction from the estate, and is neither discriminatory nor manifestly arbitrary.

9. Section 126(3) requires an effective opportunity of hearing. The representative must receive the relied-upon material and can contest the contravention, the statutory basis and the amount. Inability to give a personal account of the deceased's affairs cannot be treated as an admission, and an appeal remains available. That a particular adjudication may fail for want of evidence or a fair hearing does not make every determination after death unfair.

10. A department holding money deposited during investigation must establish a subsisting lawful basis for continued retention. A deposit pending investigation does not confer a right to indefinite retention.