
The Court held that the income tax reassessment notices issued in 2016 to Prannoy Roy and Radhika Roy were legally unsustainable.
It observed that the same assessment year had already been reopened earlier, and the issue of interest-free loans was examined in detail.
The Court further observed that reopening the assessment again on the same material amounted to a change of opinion, which is impermissible under law. The Court quashed the notices and all consequential proceedings.
It also imposed costs of ₹2 lakh on the Income Tax Department for arbitrary action.
MananBookmark