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MoneyWireTax tribunal showed undue haste, recklessness in Patanjali Ayurved order - HC

Tax tribunal showed undue haste, recklessness in Patanjali Ayurved order - HC

This story was originally published at 15:51 IST on 15 September 2026
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Informist, Tuesday, Sept. 15, 2026

 

NEW DELHI – The Delhi High Court has pulled up the members of the Income Tax Appellate Tribunal for "undue haste" and "recklessness" in passing and signing an order, involving the income tax department and Patanjali Ayurved Ltd. Such type of negligence cannot be countenanced by the appellate authorities, who are sitting in the highest pedestal of the appellate rung entrusted with fact finding inquiry, said the high court.

 

"These appeals portray a rather shocking picture of the procedural lapses and opaqueness in which the Income Tax Appellate Tribunal, the highest fact-finding body, has been passing the orders in a zeal rather over-anxiety of disposing the cases," said a bench of Justice Dinesh Mehta and Justice Rajneesh Kumar Gupta. The members of appellate tribunal have neither dealt with any contention of Patanjali Ayurved nor have, they discussed the issues involved in the appeals regarding its assessment proceedings and disposed of seven appeals, through an order which does not even contain seven paragraphs, said the bench. "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," said the court.

 

The high court set aside the appellate tribunal's 2025 order that had rejected the income tax department pleas against Patanjali Ayurved on the assessment order passed against the company for assessment years 2013-14 (Apr-Mar) to 2015-16 and assessment year 2017-18. A copy of its order be sent to the president of the appellate tribunal and the secretary of the Ministry of Law and Justice for information purposes, said the court. The president of the appellate tribunal is directed to ensure that these appeals are heard by any bench other than the ones which had passed this order, court said.

 

Earlier, the appellate tribunal had held that once the assessing officer had issued notice under Section 153C of the Income Tax Act, 1961 in 2021, all these assessment years were "unabated" ones and had rejected the income tax department's contentions. Section 153C of the Income Tax Act governs the assessment or reassessment of income for a person who was not directly searched, but whose seized assets or documents were found during a search conducted on someone else. The case involved search and seizure into a company that culminated in the proceedings under Section 153C, wherein it was found that non-genuine bills of products were provided to Patanjali Ayurved, the parent of Patanjali Foods Ltd. 

 

"On perusal of the impugned (appellate tribunal) order, we are unable to comprehend anything out of it, as it is bereft of any logic, reasoning or rationale behind it," said the high court. Apart from the procedural lacuna, it fails to understand that how a common order can be passed and released in relation to four appeals of Patanjali Ayurved, which were heard and the order was pronounced on Aug. 6, 2025, whereas other three appeals by the income tax department were heard and order was pronounced on Aug. 13, 2025, said the court.

 

At 1437 IST, the shares of Patanjali Foods Ltd. were down 1.2% at INR 336.85 on the National Stock Exchange.  End

 

IST, or Indian Standard Time, is five-and-a-half hours ahead of GMT

 

Reported by Surya Tripathi

Edited by Akul Nishant Akhoury

 

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