Overview
- A division bench of Justices Dinesh Mehta and Vinod Kumar set aside the March 31, 2016 notices and nullified all consequential proceedings.
- The court directed the Income Tax Department to pay ₹1 lakh each to Prannoy Roy and Radhika Roy as token costs.
- Judges ruled the reassessment bid amounted to a prohibited change of opinion, terming the action arbitrary, without jurisdiction, and violative of Articles 14, 19(1)(g) and 300A.
- The notices concerned alleged interest-free loans involving promoter RRPR Holding, with officials earlier alleging a ₹403.85 crore loan and related share transfers as colourable transactions.
- The Roys challenged the notices in 2017 and secured a stay; a detailed written judgment is awaited, and a similar notice to RRPR was quashed by a separate bench in September 2024.