The Delhi High Court has criticized the Income Tax Appellate Tribunal (ITAT) for “procedural lapses”, lack of transparency and “undue haste” while passing an order disposing of seven appeals concerning Patanjali Ayurved Limited.

A Division Bench comprising Justice Dinesh Mehta and Justice Rajneesh Kumar Gupta observed that the Tribunal, being the “highest fact-finding body”, had passed an order which did not deal with the contentions of the company or discuss the issues involved in the appeals.

The Court was dealing with a batch of appeals filed by the Principal Commissioner of Income Tax against Patanjali Ayurved Limited.

The Bench expressed concern over the fact that four appeals were shown as having been heard and pronounced on August 06, 2025, while another three appeals were heard and pronounced on August 13, 2025, yet a common order was passed deciding all the seven appeals.

Noting that the impugned ITAT order comprised less than seven paragraphs, the Bench said:

“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,” it added.

The Court also observed that the Members of the ITAT have shown “undue haste rather recklessness” while passing and signing the impugned order, and that even their staff failed to bring it to their notice while getting the order signed.

Observing that such type of negligence cannot be countenanced, the Court said:

“The Appellate Authorities, who are sitting in the highest pedestal of the appellate rung entrusted with fact finding inquiry.”

While clarifying that it was not examining the merits of the tax dispute, the Court set aside the impugned orders by saying that it has no other option.

It also set aside the orders which were not directly under challenge, noting that the Tax Department may not have appealed against them due to monetary limits prescribed by the Central Board of Direct Taxes (CBDT).

The appeals were restored to their original numbers for fresh consideration by the Tribunal. The Bench also directed that the matters be heard by a Bench other than the one which had passed the impugned order.

The Court directed that a copy of its order be sent to the President of the ITAT as well as the Secretary, Ministry of Law and Justice for information.

Title: Pr. Commissioner of Income Tax, Central-1, Delhi v. Patanjali Ayurved Limited & other connected matters

Click here to read order