The Delhi High Court has set aside seven orders passed by the Income Tax Appellate Tribunal (ITAT) in appeals concerning Patanjali Ayurved Ltd., expressing serious concern over procedural lapses, non-application of mind and undue haste displayed by the Tribunal while disposing of the matters.
A Division Bench of Justice Dinesh Mehta and Justice Rajneesh Kumar Gupta noted that the ITAT had disposed of seven appeals in a common order containing fewer than seven paragraphs, without dealing with the assessee’s contentions or discussing the issues involved. The Court clarified that it was not concerned with the length of the order but was particularly disturbed by the lack of application of mind.
The Court also flagged a serious procedural discrepancy. Four appeals were shown as heard and pronounced on August 6, 2025, while the remaining three appeals were shown as heard and pronounced on August 13, 2025, yet a common order had been passed and issued in respect of all seven appeals.
The High Court observed that the impugned order was “bereft of any logic, reasoning or rationale” and held that the Tribunal members had displayed “undue haste rather recklessness” while passing and signing the order. The Court observed that such negligence could not be countenanced, particularly since the ITAT occupies the highest level of the appellate fact-finding hierarchy.
The underlying appeals arose from proceedings under Section 153C of the Income Tax Act, 1961, concerning assessment years 2013-14 to 2015-16 and 2017-18. The ITAT had treated these assessment years as “unabated” and quashed the assessments, relying on the Supreme Court’s decision in PCIT v. Abhisar Buildwell Pvt. Ltd., (2023) 454 ITR 212 (SC).
The High Court, without entering into the merits of the underlying tax dispute, quashed all seven ITAT orders and directed the Tribunal to reconsider the appeals afresh.
The Court further directed that the appeals be heard by a Bench other than the one which had passed the impugned orders and forwarded a copy of its judgment to the President of the ITAT and the Secretary, Ministry of Law and Justice. It clarified that no observations had been made on the merits and that the Tribunal would be free to decide the matters independently in accordance with law.
