PCIT Vs Patanjali Ayurved Limited (Delhi High Court)
Summary: The Delhi High Court set aside the orders passed by the Income Tax Appellate Tribunal in seven cross-appeals concerning Patanjali Ayurved Limited after finding serious procedural lapses and absence of adequate reasoning in the Tribunal’s common order. The four appeals filed by the assessee, ITA Nos. 534 to 537/Del/2025 for AYs 2013-14 to 2015-16 and 2017-18, had been recorded as heard and pronounced on 06.08.2025, whereas the Revenue’s three cross-appeals, ITA Nos. 605 to 607/Del/2025 for AYs 2014-15, 2013-14 and 2015-16, showed their hearing and pronouncement date as 13.08.2025. Nevertheless, a single common order was issued for all seven appeals.
The High Court observed that the Tribunal had neither dealt with the assessee’s contentions nor discussed the issues involved and had disposed of seven appeals through an order that did not even contain seven paragraphs. When the High Court initially considered the matter, counsel for the assessee also sought to verify the position from the record and certified copies and subsequently acknowledged an apparent procedural error on the Tribunal’s part, possibly due to inadvertence. The Revenue submitted that the Tribunal had treated the relevant assessment years as “unabated” because the Assessing Officer had issued notice under Section 153C of the Income Tax Act, 1961 on 06.08.2021. The High Court, however, found the impugned order bereft of logic, reasoning or rationale and questioned how one common order could have been passed for appeals heard and pronounced on two different dates.
