The Delhi High Court has set aside seven orders passed by the Income Tax Appellate Tribunal (ITAT) in cross-appeals involving Patanjali Ayurved Limited, sharply criticising how the matters were disposed of and describing the proceedings as a "shocking picture" of procedural lapses and a lack of transparency.
Why the Court Questioned a Single Common Order
A bench comprising Justices Dinesh Mehta and Rajneesh Kumar Gupta, in a judgment dated September 10 and uploaded on September 15, took serious exception to the ITAT passing a single common order across all seven matters, appeals filed separately by Patanjali Ayurved and the Revenue Department, despite different dates having been fixed for pronouncement of orders in the two sets of appeals.
The court found that the ITAT neither addressed the contentions raised by the assessee nor examined the actual issues involved in the appeals, instead disposing of all seven matters through an order comprising fewer than seven paragraphs, remarkably brief given the scale and complexity of what was being decided.
Judges Flag "Undue Haste, Rather Recklessness"
The bench went further, observing that the Tribunal's Members had displayed "undue haste, rather recklessness" in passing and signing the order, while tribunal staff also failed to flag the errors before the order was signed. The court held that such negligence couldn't be excused, particularly from appellate authorities sitting at the highest rung of the fact-finding appellate hierarchy.
In the court's own words: "These appeals portray a rather shocking picture of the procedural lapses and opaqueness in which the Income Tax Appellate Tribunal (hereinafter referred to as 'the Tribunal'), the highest fact-finding body, has been passing the orders in a zeal rather over-anxiety of disposing the cases. 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 bench added: "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. It is therefore clear that the learned Members have shown undue haste rather recklessness while passing and signing the order, and even their staff failed to bring it to notice of the learned Members while getting the order signed."
A Discrepancy in Hearing and Pronouncement Dates
The court also flagged a notable inconsistency in the recorded dates: four appeals were shown as having been heard and pronounced on August 6, 2025, while the same common order also covered three revenue appeals recorded as heard and pronounced on August 13, 2025, a discrepancy that itself raised questions about how carefully the order had actually been prepared and reviewed before being signed.
The Case's Background
These orders arose while the High Court was dealing with appeals filed by the Income Tax Commissioner challenging the ITAT's August 6 and 13 orders, which had quashed the assessment proceedings against Patanjali and allowed the company's appeals. With the seven ITAT orders now set aside, the underlying matters will presumably need fresh consideration by the tribunal, this time with the procedural rigour the High Court found lacking.
FAQs
Q1. What did the Delhi High Court set aside in this ruling?
Seven orders passed by the ITAT in cross-appeals involving Patanjali Ayurved Limited and the Revenue Department.
Q2. Why did the court criticise the ITAT's handling of the case?
Because the Tribunal issued a single common order across all seven matters, spanning fewer than seven paragraphs, without addressing the parties' contentions or examining the actual issues, despite the appeals having different hearing and pronouncement dates.
Q3. What specific language did the court use to describe the ITAT's conduct?
The court described it as showing "undue haste, rather recklessness," calling the order "bereft of any logic, reasoning or rationale."
Q4. What discrepancy did the High Court point out in the ITAT's order?
Four appeals were recorded as heard and pronounced on August 6, 2025, while three revenue appeals in the same common order were recorded as heard and pronounced on August 13, 2025.