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The Delhi High Court has quashed the income tax reassessment notices issued in March 2016 to NDTV founders Prannoy Roy and Radhika Roy. The court also imposed a total cost of ₹2 lakh on the Income Tax Department, directing that ₹1 lakh be paid to each petitioner. The notices related to alleged interest-free loans advanced to RRPR Holding Pvt. Ltd, a promoter group of NDTV. The detailed judgment is awaited.
According to Live Law, the Division Bench of Justices Dinesh Mehta and Vinod Kumar found that the tax department’s attempt to revisit transactions involving RRPR Holding Pvt. Ltd. was improper, as these had already been examined in an earlier assessment cycle. The court agreed with the Roys’ argument that reopening assessments on identical issues amounted to an impermissible “change in opinion” under the Income Tax Act.
As reported by Scroll, the Roys had approached the High Court in November 2017, contending that the reassessment proceedings constituted a second reopening for the same assessment year. They submitted that the department had already reopened the assessment in July 2011, which concluded with a reassessment order in March 2013. The bench held that the department could not revisit issues already examined during the earlier reassessment.
The court imposed costs on the tax authorities, stating that while no amount of cost could be enough for such cases, it was necessary to impose a token penalty. Coverage revealed that all proceedings following from the reassessment notices were also quashed. The Roys’ counsel argued that the department’s claim of a limited scope in the earlier reassessment was incorrect, as once a reassessment is initiated, the entire under-assessed income can be examined.
“No amount of cost can be treated as enough for these cases. However, we cannot leave these cases without imposing any,” the bench stated.
As highlighted by Bar and Bench, the court also noted that similar reassessment proceedings against RRPR Holding Pvt. Ltd. are already pending before the High Court, with a stay on final orders in place. The notice to RRPR was quashed by a separate bench in September 2024. Senior Advocate Sachit Jolly appeared for the Roys, while the Income Tax Department was represented by a separate legal team.
The bench concluded that the department’s actions amounted to a prohibited “change of opinion” and reiterated that reopening the same matter after a completed reassessment is not permitted under law as details emerged.
In its order, the court clarified that all consequent proceedings initiated pursuant to the quashed notices would also be set aside following reports from the hearing. The detailed written judgment is expected to provide further legal reasoning and guidance for similar cases in the future.
“Both the writ petitions are allowed. Notices dated March 31, 2026, issued to the petitioners and any consequent order or proceedings thereto are quashed,” the court ordered.
Note: This article is produced using AI-assisted tools and is based on publicly available information. It has been reviewed by The Quint's editorial team before publishing.