Bench: Itat, Stating That The Reopening Of Assessment U/S 147 Of The Act Was Based Merely On System Generated Information, Which Is Invalid & Without Any Tangible Material. In The Grounds Of Appeal, It Was Mentioned That The Assessment U/S 147 Is Beyond Time Limit Prescribed & Hence, The Proceedings Are Void-Ab-Initio.

271(1)(c) of the Income Tax Act, 1961 (“the Act”), dated 22.03.2024 and 20.09.2024 respectively, pertaining to the assessment year 2016-17. 2. The appellant filed an appeal before ITAT, stating that the reopening of assessment u/s 147 of the Act was based merely on system generated information, which is invalid and without any tangible material. In the grounds