The assessee, a Singapore tax resident and Category III FPI, invested about Rs. 448 crores in Non-convertible Debentures (NCDs) of an Indian company (SVHPL). It earned interest of about Rs. 8.24 crores on these NCDs, on which tax was deducted under section 194LD. Relying on section 115A(5), the assessee did not file its return. Based on information received through the Non-filers Management System, the AO issued a notice under section 148 and conducted a reassessment. The AO noted that the NCD investment was funded by the Singapore holding company, treated the assessee as a shell entity, and added the NCD subscription of Rs.448 crores as unexplained business income. The AO further added interest of about Rs. 8.24 crores. On objections, the DRP sustained the additions. Pursuant to remand directions in connected writ proceedings, the DRP issued second-round directions, again upholding the draft order. Consequent to these directions, the AO passed the final reassessment order. On appeal to the ITAT, it was held that the AO reopened the assessment solely on an NMS non-filing alert, without independent verification or proper reasons, despite being aware that assessee was a non-resident with only TDS-deducted interest income. Thus, such reassessment was held to be void ab initio. [AY. 2015-16, 2017-18]