Delhi High Court remands Patanjali Ayurved ITAT appeals over procedural irregularities and lack of reasoning
Background of the dispute
The Delhi High Court, in PCIT Vs Patanjali Ayurved Limited (ITA 80/2026 & CM APPL. 6824/2026, judgment dated 15/09/2026, AY 2014-15), examined a batch of appeals arising from a common order of the Income Tax Appellate Tribunal (ITAT) concerning Patanjali Ayurved Limited. The Court found substantial procedural defects in the Tribunal’s handling of seven connected appeals and therefore set aside the entire set of ITAT orders, directing a fresh adjudication.
The matter involved:
Four appeals filed by the assessee:
ITA Nos. 534 to 537/Del/2025- Assessment Years:
2013-14,2014-15,2015-16,2017-18 - All shown as heard and pronounced on
06.08.2025
Three cross-appeals filed by the Revenue:
ITA Nos. 605 to 607/Del/2025- Assessment Years:
2014-15,2013-14,2015-16 - Hearing and pronouncement date recorded as
13.08.2025
Despite these different hearing and pronouncement dates, the Tribunal issued a single common order covering all seven appeals.
The High Court confined itself to the procedural and reasoning aspects of the Tribunal’s order and explicitly refrained from deciding any issue on merits relating to additions, assessments or the legal position on Section 153C or “unabated” assessments.
High Court’s concern over ITAT’s functioning
Inadequate reasoning and non-consideration of contentions
The High Court expressed clear displeasure with the manner in which the Tribunal had dealt with the appeals. It underlined that:
- The Tribunal did not address the assessee’s arguments.
- The Tribunal did not discuss the issues involved in any meaningful way.
- Seven appeals were disposed of through a very brief order, which the Court noted did “not even contain seven paragraphs.”
The Court emphasised that its concern was not with the length of the order per se, but with:
- Absence of proper application of mind, and
- Undue haste displayed in deciding multiple appeals involving different years and parties’ contentions.
As the ITAT is the highest fact-finding appellate forum under the Income Tax Act 1961, the Court noted that such lack of reasoning and procedural care was unacceptable.
Procedural anomaly in hearing and pronouncement dates
One of the most striking features for the High Court was the discrepancy in how the Tribunal recorded the hearing and pronouncement of the appeals:
The assessee’s four appeals (
ITA Nos. 534 to 537/Del/2025) showed:- Date of hearing:
06.08.2025 - Date of pronouncement:
06.08.2025
- Date of hearing:
The Revenue’s three cross-appeals (
ITA Nos. 605 to 607/Del/2025) showed:- Date of hearing:
13.08.2025 - Date of pronouncement:
13.08.2025
- Date of hearing:
Yet, all seven matters were disposed of by one common order, which was stated to have been pronounced in open court on “6th & 13th August, 2025”. The High Court observed that it was unable to understand:
- How appeals heard and pronounced on two different dates could validly be decided by a single common order, and
- How such an order could be issued without clearly and logically reflecting that process.
This inconsistency formed a core basis for the Court’s conclusion that there were serious procedural lapses.
Parties’ submissions before the High Court
Response of the assessee’s counsel
When the matter was first listed on 02.02.2026, counsel for the assessee, `Mr.