As per case facts, Ms. Radhika Roy and Dr. Prannoy Roy challenged reassessment notices for AY 2009-10. Earlier, a first reassessment for Ms. Roy (and implicitly Dr. Roy via the ... common issue) had examined an interest-free loan from RRPR Holding Private Limited, with the AO choosing not to make any addition for deemed dividend. A second reassessment notice for the very same AY and issue was later issued, based on a complaint about the interest-free loan. The petitioners approached the High Court arguing that the re-initiation was arbitrary and without jurisdiction as the issue was already examined and dropped. The question arose whether tax authorities could re-initiate reassessment on an issue previously concluded, or based on a mere change of opinion, and if the extended limitation period was valid despite primary fact disclosure. Finally, the High Court ruled the second reassessment for the same transaction and issue as arbitrary and without jurisdiction, violating fundamental rights. It held that a mere change of opinion by new incumbents does not justify re-opening, and the extended limitation was baseless as primary facts were disclosed. The impugned notices were quashed.