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‘Bereft of logic’: Delhi HC’s earful to ITAT over orders, handling of Patanjali income tax appeals
The court set aside all 7 orders and restored the matters for fresh consideration before a different ITAT bench, making clear that it had not expressed opinion on merits of the tax dispute.
New Delhi: The Delhi High Court has quashed all seven orders passed by the Income Tax Appellate Tribunal (ITAT) in tax appeals involving Patanjali Ayurved Limited, flagging what it called a “shocking picture” of procedural lapses and expressing strong displeasure over the manner in which the tribunal handled the cases.
A bench of Justices Dinesh Mehta and Rajneesh Kumar Gupta said the ITAT order reflected “non-application of mind” and “undue haste”, besides being “bereft of any logic, reasoning or rationale”. The court also referred to a “procedural lacuna” and said the tribunal members had shown “undue haste rather recklessness” in passing and signing the order.
The appeals before the high court were filed by the income tax department, with Patanjali as the respondent. The revenue department challenged the ITAT orders that had earlier granted relief to Patanjali in four appeals.
The high court set aside all seven orders and restored the matters for fresh consideration before a different ITAT bench, while making clear that it had not expressed any opinion on the merits of the tax dispute.
The procedural issue arose from the manner in which the seven appeals were disposed of by the tribunal. Four appeals filed by Patanjali ITA 534 to 537/Del/2025 concerning assessment years 2013-14 to 2015-16 and 2017-18, were heard and pronounced on 6 August 2025.
Three cross-appeals filed by the revenue department ITA 605 to 607/Del/2025 showed 13 August 2025 as both the date of hearing and date of pronouncement.
Despite the different dates, a common order was passed on 13 August on the cross-appeals filed by the opposites sides. The high court asked how one order could cover appeals heard and pronounced a week apart. The court also noted that the ITAT order contained fewer than seven paragraphs. It clarified that the brevity was not the issue, but the lack of reasoning and application of mind was.