Shocking opaqueness: Delhi HC slams ITAT for passing order in Patanjali case without application of mind

The Delhi High Court recently quashed 7 orders passed by the Income Tax Appellate Tribunal (ITAT) in a batch of cross-appeals involving Patanjali Ayurved Limited, stating that they portray a “shocking picture” of the procedural lapses and opaqueness in which the ITAT is functioning  [Pr Commissioner of Income Tax, Central 1 Delhi v Patanjali Ayurved Limited]. 

A Division Bench of Justices Dinesh Mehta and Rajneesh Kumar Gupta was dealing with a batch of appeals filed by the Principal Commissioner of Income Tax, Central-1, Delhi, against Patanjali Ayurved. The case arose from 7 appeals before the ITAT relating to assessment years 2013-14 to 2015-16 and 2017-18.

After examining the ITAT order, the High Court said that it reflected that the Tribunal had been passing orders in “over-anxiety” of disposing of the matters.

“In the order under consideration, where the learned Members of the Tribunal have neither dealt with any contention of the assessee nor have, they discussed the issues involved in the appeals and disposed of seven appeals, vide an order which does not even contain seven paragraphs. We are not much concerned with the size of the order but what shocks us is, the non-application of mind and undue haste which learned Members of the Tribunal have exhibited,” the Court said. 

The Court noted that the Tribunal orders recorded contradictory dates of hearing and pronouncement for different sets of appeals within the same batch. 

“On perusal of the impugned order, we are unable to comprehend anything out of it, as it is bereft of any logic, reasoning or rationale behind it. Apart from the procedural lacuna, we fail to understand that how a common order can be passed and released in relation to four appeals, which were heard and qua which the order was pronounced on 06.08.2025, whereas other three appeals were heard and order was pronounced on 13.08.2025,” the Court observed. 

Therefore, the High Court set aside all 7 orders and asked the President of the ITAT to ensure that cases are heard afresh by another bench. It also sent its order to the Secretary of the Ministry of Law and Justice for information.

Senior Standing Counsel (SSC) Puneet Rai along with Advocates Ashvini Kr, Rishabh Nangia, Nikhil Jain and Nancy Jain represented the Income Tax Department. 

Advocates Vaibhav Kulkarni and Sandip Nagar appeared for Patanjali. 

[Read Order]