Judicial Rebuke: IT Department’s Action Against Prannoy and Radhika Roy Labelled as Harassment

(By Syed Ali Taher Abedi)

Delhi 19, January,2026-

In a significant judicial rebuke of the Revenue authorities, the Delhi High Court on Monday quashed the reassessment proceedings initiated against NDTV founders Prannoy Roy and Radhika Roy, characterizing the Income Tax Department’s persistent actions as “harassment.”

“In the extant case, we are more than surprised to find that the very fact which is a foundational fact, was there in the knowledge of the AO who has passed the order dated 30.03.2013, pursuant to the notice dated 25.07.2011 issued under the very same provision i.e. 148 of the Act of 1961.”

A Division Bench comprising Justice Dinesh Mehta and Justice Vinod Kumar delivered a scathing indictment of the Department’s conduct, observing that the repeated reopening of tax assessments creates an environment of “uncertainty and anarchy.”

Procedural History and Judicial Reasoning

The legal dispute centred on an interest-free loan advanced by RRPR Holding Pvt. Ltd. (the promoter group of NDTV) to the Roys. The Revenue had sought to tax the “notional interest” on this loan as deemed income.

The court’s decision rested on several key legal pillars:

• The Doctrine of Finality: The Bench noted that the first reassessment proceedings were initiated as far back as 2011, resulting in no additions to the taxable income. The court held that the authorities cannot perpetually trigger proceedings over the same transaction.
• Impermissible Change of Opinion: The court upheld the petitioners’ contention that the 2016 notices constituted a mere “change of opinion” rather than the discovery of new, tangible evidence, which is a jurisdictional requirement under Section 147/148 of the Income Tax Act.
• Arbitrary Use of Limitation Periods: The Court found that the Department’s attempt to use extended limitation periods to reopen assessments for the 2009-10 period was arbitrary and contrary to the statutory mandate.
• Consistency in Law: The Roys’ counsel successfully cited a 2024 precedent where similar reassessment notices against RRPR Holding had already been quashed by the court.
• “Initiation of reassessment proceedings in such circumstances, leads to unnecessary harassment of an assessee on the one hand and give rise to unpredictability/uncertainty, if not anarchy on the other

Final Orders and Costs

In a rare move reflecting the court’s displeasure with the misuse of state machinery, the Bench imposed a cost of ₹2 lakh on the Income Tax Department.

“In the instant case, subjecting the petitioner to reassessment proceedings second time for the self-same 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.

“The tax authorities cannot be permitted to subject taxpayers to endless litigation by reopening settled matters without fresh material,” the court observed, emphasizing that such actions undermine the rule of law.

Legal Representation

• For the Petitioners (Prannoy and Radhika Roy): Senior Advocate Sachit Jolly, appearing with Advocates Viyushti Rawat, Devansh Jain, and Sarthak Abrol.
• For the Respondents (IT Department): Advocates NP Sahni, Indrajit Singh Rai, Sanjeev Menon, Rahul Singh, and Gaurav Kumar.