The Delhi High Court on Monday set aside the income tax reassessment notices issued in March 2016 to NDTV founders Prannoy and Radhika Roy concerning certain interest-free loans extended by NDTV promoter company RRPR Holding Pvt Ltd.A Division Bench comprising Justices Dinesh Mehta and Vinok Kumar not only quashed the impugned notices but also imposed costs of Rs 2 lakh on the Income Tax Department, directing it to pay Rs 1 lakh each to the two petitioners.“As a conclusion to the foregoing discussion, both the writ petitions are allowed. Notices dated March 31, 2016, issued to the petitioners and any consequent order or proceedings thereto are quashed. No amount of cost can be treated as enough for these cases. However, we cannot leave these cases without imposing any cost. Hence, we impose a token cost of Rs 1 lakh to be paid by the respondents to each of the petitioners,” the court ordered.The Bench further clarified that all proceedings arising out of these notices would also stand quashed.The dispute stems from interest-free loans advanced by RRPR Holding Pvt Ltd, a company in which Prannoy and Radhika Roy served as directors and held 50 per cent shareholding.The Income Tax Department had first reopened the Roys’ assessments in 2011 for the assessment year 2009-2010, scrutinising transactions involving NDTV shares as well as the loans received from RRPR. After examining the matter, the assessing officer concluded the reassessment in March 2013 without making any additions in relation to the interest-free loans.Despite this, the department issued fresh reassessment notices in 2016, proposing to treat the notional interest on those loans as “deemed income” under Section 2(24)(iv) of the Income Tax Act, citing complaints and additional records received after RRPR’s jurisdiction was transferred.Challenging this second round of reassessment, the Roys moved the High Court in November 2017, arguing that the department was effectively reopening the same assessment for a second time. They contended that the issues now raised had already been examined during the earlier reassessment proceedings that culminated in the March 2013 order.They further challenged the assessing officer’s stand that the earlier reassessment was limited in scope, maintaining that once reassessment is initiated, the entire alleged under-assessed income can be examined. The petitioners also submitted that the department’s action amounted to a “change of opinion”, which is not permissible under the law.The court was also apprised that similar reassessment proceedings against RRPR Holding Pvt Ltd itself are pending before the High Court and that a stay on final orders has been granted in those matters. The reassessment notice issued to RRPR was quashed by another bench of the High Court in September 2024.