Supreme Court Dismisses IT Dept Challenge To Quashing Of Reassessment Notice Against NDTV Holding Company

The Supreme Court today dismissed the Income Tax Department's appeal against the Delhi High Court judgment which had quashed reassessment proceedings against RRPR Holdings Private Limited, a company owned by NDTV promoters Radhika Roy and Prannoy Roy.

A bench of Justice PS Narsimha and Justice Alok Aradhe dismissed the appeal on the ground of delay.

In 2009, RRPR Holdings took a loan from Vishwa Pradhan Commercial Pvt. Ltd. It claimed that the loan proceeds were utilized clear outstanding loans with the ICICI Bank.

However, the Assessment Officer opined that as per the terms of the loan agreement, the loan was actually payment for transfer of 26% shares of NDTV. Thus, a notice was issued to RRPR Holdings for the Assessment Year 2010-11 for reassessment of taxable income during the Financial Year 2009-10. RRPR Holdings challenged the reassessment notice before the Delhi High Court.

On September 10, 2024, the Delhi High Court rejected the AO's observation as factually incorrect. It noted that RRPR Holdings had acquired 7.5% shareholding in NDTV which continued to be held by it and were never transferred to the lender.

Holding that the very basis of the reassessment action was erroneous, the High Court quashed the reassessment notice dated March 23, 2015 issued under Section 148 of the Income Tax Act.

Case no. – Diary No. - 74314/2025

Case Title – Deputy Commissioner Of Income Tax v. RRPR Holdings Private Limited