Delhi High Court Sets Aside ITAT Common Order For Procedural Lapses And Restores Appeals
The Case
PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI Vs PATANJALI AYURVED LIMITED
Case No.: ITA/83/2026
Decided on: 09/10/2026
CNR: DLHC010032562026 ·
High Court of Delhi
The Legal Issue
Whether the Income Tax Appellate Tribunal's common order, passed in a batch of seven appeals and showing different dates of hearing and pronouncement, could be sustained. The Court examined whether the order reflected non-application of mind and undue haste, and whether it could be set aside on procedural grounds.
Facts of the Case
The assessee, Patanjali Ayurved Limited, and the Revenue had filed cross-appeals before the Income Tax Appellate Tribunal. The Tribunal passed a common order in seven appeals: four assessee appeals (ITA Nos. 534 to 537/Del/2025) and three Revenue appeals (ITA Nos. 605 to 607/Del/2025). The order showed that four appeals were heard and pronounced on 06.08.2025, while three were heard and pronounced on 13.08.2025, yet a common order was passed and issued. The Tribunal quashed the assessments, observing that once notice under Section 153C was issued on 06.08.2021, all assessment years were 'unabated'. The Revenue appealed to the High Court.
Summary of the Decision
The High Court set aside all seven orders passed by the Tribunal, including those not under challenge due to monetary limits. The Court found that the impugned order was bereft of any logic, reasoning, or rationale and exhibited non-application of mind and undue haste. The Court noted that a common order could not have been passed for appeals heard and pronounced on different dates, namely 06.08.2025 and 13.08.2025. Consequently, the appeals bearing ITA Nos. 534 to 537/Del/2025 and ITA Nos. 605 to 607/Del/2025 were restored to their original numbers to be decided afresh by the Tribunal. The Court directed that the President of the Tribunal ensure these appeals are heard by any Bench other than the Bench which passed the impugned order. A copy of the order was to be sent to the President of the Tribunal and the Secretary of the Ministry of Law and Justice for information. The Court clarified that it had not made any observation on the merits of the case, and the Tribunal would be free to take an independent view in accordance with law.
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