Delhi High Court Criticizes ITAT’s Handling of Patanjali Case
The Delhi High Court has recently annulled seven orders issued by the Income Tax Appellate Tribunal (ITAT) concerning a series of cross-appeals involving Patanjali Ayurved Limited. The court expressed significant concerns over procedural shortcomings and the lack of transparency in ITAT’s operations, describing the situation as a “shocking picture” [Pr Commissioner of Income Tax, Central 1 Delhi v Patanjali Ayurved Limited].
A Division Bench consisting of Justices Dinesh Mehta and Rajneesh Kumar Gupta reviewed the appeals initiated by the Principal Commissioner of Income Tax, Central-1, Delhi against Patanjali Ayurved. These appeals were associated with assessment years ranging from 2013-14 to 2015-16 and 2017-18. Upon review, the High Court remarked that the ITAT seemed to be overly eager to resolve cases, leading to hasty and inadequately reasoned decisions.
The High Court highlighted that the ITAT’s order failed to address any arguments presented by the assessee and lacked any substantive discussion of the issues at hand. The problematic order disposed of seven appeals in a document that did not even extend to seven paragraphs. The court clarified, “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.”
Furthermore, the court noted discrepancies in the ITAT’s recorded hearing and pronouncement dates for different appeals within the same series. The court stated, “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 how a common order can be passed and released in relation to four appeals, which were heard and for which the order was pronounced on 06.08.2025, whereas other three appeals were heard and order was pronounced on 13.08.2025.”
In response, the High Court vacated all seven orders and directed the President of the ITAT to ensure that these cases are reheard by a different bench. Additionally, the court forwarded its decision to the Ministry of Law and Justice’s Secretary for further consideration.
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The Income Tax Department was represented by Senior Standing Counsel Puneet Rai and Advocates Ashvini Kr, Rishabh Nangia, Nikhil Jain, and Nancy Jain. Advocates Vaibhav Kulkarni and Sandip Nagar represented Patanjali.
