RADHIKA ROY vs DEPUTY COMMISSIONER OF INCOME -TAX CIRCLE 18(1) & ANR.

Judgment text excerpt

$~J- * IN THE HIGH COURT OF DELHI AT NEW DELHI Reserved on :06th January, 2026 Pronounced on :19th January, 2026 + W.P.(C) 10527/2017 RADHIKA ROY ......Petitioner Through: Mr. Sachit Jolly, Sr. Adv. with Ms. Viyushti Rawat, Mr. Devansh Jain and Mr. Sarthak Abrol, Advs. versus DEPUTY COMMISSIONER OF INCOME -TAX CIRCLE 18(1) &ANR. ......Respondents Through: Mr. N. P. Sahni, Spl. Counsel with Indruj Singh Rai, SSC, Mr. Sanjeev Menon, JSC, Mr. Rahul Singh, JSC and Mr. Gaurav Kumar, Advs. + W.P.(C) 10529/2017 DR. PRANNOY ROY .....Petitioner Through: Mr. Sachit Jolly, Sr. Adv. with Ms. Viyushti Rawat, Mr. Devansh Jain and Mr. Sarthak Abrol, Advs. versus DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE 18(1) &ANR. .....Respondents Through: Mr. N. P. Sahni, Spl. Counsel with Indruj Singh Rai, SSC, Mr. Sanjeev Menon, JSC, Mr. Rahul Singh, JSC and Mr. Gaurav Kumar, Advs. CORAM: HON'BLE MR. JUSTICE DINESH MEHTA HON'BLE MR. JUSTICE VINOD KUMAR JUDGMENT REPORTABLE Per DINESH MEHTA, J. 1. Both the Writ Petitions have been filed by the petitioners, Ms. Radhika Roy and Dr. Prannoy Roy, respectively, laying challenge to Signature Not Verified Digitally Signed W.P.(C) 10527/2017 & W.P.(C) 10529/2017 Page 1 of 16 By:NAVEEN KUMAR Signing Date:19.01.2026 14:36:55 notice(s) dated 31.03.2016 under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as “the Act of 1961”) separately issued to them. The factual matrix of both cases lie in a narrow compass and are identical, therefore, the facts of first case i.e. W.P.(C) 10527/2017 are being taken into account. 2. The petitioner, Ms. Radhika Roy, at the relevant time was having 50% shareholding in a company known as RRPR Holding Private Limited (hereinafter referred to as “RRPR”). For the assessment year (hereinafter referred to as “AY”) 20