Delhi High Court Sets Aside ITAT Common Order For Procedural Lapses In Patanjali Ayurved Case

The Case

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI Vs PATANJALI AYURVED LIMITED
Case No.: ITA/81/2026
Decided on: 09/10/2026
CNR: DLHC010032482026 ·
High Court of Delhi

The Legal Issue

The Court examined the Tribunal's common order disposing of seven appeals, where four appeals were heard and pronounced on 06.08.2025 and three appeals were heard and pronounced on 13.08.2025, yet a single common order was passed, pronounced and issued. The Court considered whether such an order, bereft of any logic, reasoning or rationale, could be sustained.

Facts of the Case

The assessee, Patanjali Ayurved Limited, and the Revenue had filed cross-appeals before the Income Tax Appellate Tribunal. The assessee filed ITA Nos. 534 to 537/Del/2025, and the Revenue filed ITA Nos. 605 to 607/Del/2025. The Tribunal passed a common order dated 6th & 13th August, 2025, which quashed the assessments and allowed the assessee's appeals and dismissed the Revenue's appeals. On perusal of the certified copies, the Court found that the Tribunal had heard four appeals on 06.08.2025 and three on 13.08.2025, but passed a single common order covering all seven appeals.

Summary of the Decision

The Court set aside all seven orders passed by the Tribunal, including those not under challenge due to monetary limits, and restored ITA Nos. 534 to 537/Del/2025 and ITA Nos. 605 to 607/Del/2025 to their original numbers for fresh decision by the Tribunal. The Court found that the Tribunal had shown undue haste and recklessness, and that the order was bereft of any logic, reasoning or rationale. The Court directed that the copy of the order be sent to the President of the Tribunal and the Secretary of the Ministry of Law and Justice, and that the President ensure the appeals are heard by any Bench other than the one which passed the order. The Court clarified that it had not made any observation on merits, and the Tribunal shall be free to take an independent view. The appeals were disposed of in these terms, and pending applications also stood disposed of.

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