Supreme Court Dismisses Income Tax Department SLP Against NDTV Holding Company RRPR Over 372-Day Delay

The Supreme Court on Thursday dismissed special leave petitions filed by the Income Tax Department against RRPR Holdings Pvt Ltd, the promoter holding company of NDTV, on the ground of a delay of 372 days, declining to condone the inordinate delay and leaving undisturbed the Delhi High Court's ruling quashing reassessment proceedings.

Holding that no bona fide or plausible explanation had been furnished by the department, a bench of Justices Pamidighantam Sri Narasimha and Alok Aradhe observed:

“There is a delay of 372 days in filing these Special Leave Petitions and we do not find any bonafide and plausible explanation to condone this inordinate delay. The Special Leave Petitions are, accordingly, dismissed on the ground of delay.”

The petitions arose from the Delhi High Court's order dated September 10, 2024, which had quashed a reassessment notice issued under Section 148 of the Income Tax Act for Assessment Year 2010–11 against RRPR Holdings.

The High Court had held that the very foundation of the reassessment proceedings was factually incorrect. It noted that while the Revenue alleged that a loan agreement dated July 21, 2009 between RRPR and Vishwa Pradhan Commercial Pvt. Ltd. was effectively consideration for transfer of 26% shares of NDTV, it was an admitted position that the shares continued to remain with RRPR and were never transferred.

Finding the basis of the reassessment to be factually erroneous, the High Court had quashed the notice dated March 23, 2015 initiating reassessment proceedings.

Aggrieved by the ruling, the Revenue approached the Supreme Court with a delay of 372 days. Declining to condone the delay, the court dismissed the petitions.

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