ITAT says Reopening Based on Pre-Existing Investigation Information Is Void

The reassessment was triggered by an Investigation Wing report received manually in March 2020, although the same information was uploaded on the Insight Portal only on 8 March 2021. Since the reasons recorded relied on the pre-existing physical information and not on any fresh information flagged after 4 March 2021, the Tribunal held the reopening ab initio void. It further held, on merits, that the ₹1.35 crore bank deposits were satisfactorily explained.