IT Department Moves Supreme Court Against Delhi HC Order Quashing Reassessment Notices Against NDTV Founders
The Income Tax Department has challenged a Delhi High Court ruling that quashed reassessment proceedings against NDTV founders Dr. Prannoy Roy and Radhika Roy over interest-free loans received from RRPR Holdings Pvt. Ltd.
The loans included about ₹21 crore advanced to Prannoy Roy and about ₹71 crore advanced to Radhika Roy.
The Special Leave Petition is likely to be heard by a vacation bench of Justices R. Mahadevan and Alok Aradhe on June 30, 2026.
The High Court judgment delivered by a Division Bench of Justices Dinesh Mehta and Vinod Kumar on January 16, 2026 had quashed notices issued under Section 148 of the Income Tax Act for AY 2009-10. The Court held that the reassessment proceedings amounted to a second attempt to reopen a transaction that had already been scrutinised during earlier reassessment proceedings.
The dispute related to interest free loans advanced by RRPR to Prannoy Roy and Radhika Roy. The Department had first reopened the assessment in 2011 and specifically examined the loans, seeking explanations from the assessees. The proceedings culminated in an order dated March 30, 2013 without making any addition on that issue.
However in March 2016, fresh reassessment notices were issued alleging that RRPR had borrowed Rs. 375 crores from ICICI Bank at 19% interest and advanced interest free loans to the Roys, resulting in a taxable benefit under the Income Tax Act.
Rejecting the Department's stand, the High Court found that the underlying transaction, RRPR's books of accounts and all relevant records had already been examined during the earlier reassessment. It held that the second reassessment was based on the same material and amounted to an impermissible change of opinion which was arbitrary and unconstitutional.
“In the instant case, subjecting the petitioner to reassessment proceedings second time for the selfsame transaction and practically for the same issue is arbitrary and without jurisdiction. They fall foul to petitioner's fundamental and constitutional rights guaranteed under Article 14, Article 19(1)(g) and Article 300A of the Constitution of India.”
Accordingly, the reassessment notices and all consequential proceedings were quashed with costs of Rs. 1 lakh awarded to each petitioner.
In a similar case on April 2, 2026, the Supreme Court had dismissed the Income Tax Department's appeal against a separate Delhi High Court judgment that had quashed reassessment proceedings against RRPR Holdings Pvt Ltd.