The Delhi High Court quashed the second reassessment notices issued under Section 148 for AY 2009–10, holding them to be without jurisdiction and based on mere change of opinion. The issue of interest-free loans received from RRPR had already been specifically examined during the first reassessment, where no addition was made after full disclosure of facts. The Court held that reopening on the same transaction under a different provision (Section 2(24)(iv) instead of Section 2(22)(e)) was impermissible, and there was no failure to disclose material facts to justify extended limitation. Consequently, the reassessment notices and all consequential proceedings were quashed, with costs of ₹1,00,000 per case imposed on the Department.

Source Link- https://delhihighcourt.nic.in/app/showFileJudgment/75819012026CW105272017_144252.pdf