PATANJALI AYURVED LTD,DELHI vs. DCIT,CENTRAL CIRCLE-5, DELHI
Before: SHRI SATBEER SINGH GODARA & SHRI MANISH AGARWAL
PER SATBEER SINGH GODARA, JM
The instant batch of seven appeals involves the single assessee, namely, M/s. Patanjali Ayurved Ltd. This assessee and the department have filed their respective three cross appeals each
ITA Nos. ITA Nos.534 to 536/Del/2025 and ITA Nos. 606, 605 &
607/Del/2025, against the Commissioner of Income Tax (Appeals)-
24 [in short, the “CIT(A)”], New Delhi’s separate orders, dated
26.11.2024 (for AYs: 2013-14 and 2014-15) and 27.11.2024 (for AY: 2015-16), passed in case nos. CIT(A), Delhi-24/10102/2012-
13, 10194/2013-14 and 11029/2014-15, in proceedings under section 143(3) r.w.s. 153C of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), respectively. The assessee’s last appeal ITA
No.537/Del/2025 is directed against CIT(A)-24, New Delhi’s order dated
27.12.2024
passed in case no.
CIT(A),
Delhi-
24/10463/2016-17 involving proceedings under section 153C of the Act.
Heard both the parties. Case files perused.
2. We notice during the course of hearing that the instant batch of seven cases i.e. assessee’s four and the Revenue’s three cross- appeals, arises from a common search action dated 31st October to ITA No.534 to 537/Del/2025 &
605 to 607/Del/2025
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3rd November, 2018 in M/s. Hawala Traders Group leading to initiation of section 153C proceedings herein which finally culminated in the impugned assessments dated 27th March, 2023
in question. And that the learned Assessing Officer himself clarified in the assessment order(s) at page 2 para 4 that “in the case of Sh.
Sumit Jindal it was found that he has provided non-genuine bills to………….., including “M/s. Patanjali Ayurved Ltd.” i.e. the assessee. Meaning thereby that no addition herein has been made which could be held to be based on any specific incriminating or seized material during “search”; held as mandatory in PCIT Vs.
Abhisar Buildwell Pvt. Ltd. (2023) 454 ITR 212 (SC).
4. We make it clear that once the learned Assessing Officer had issued his section 153C notice on 06.08.2021, all these assessment years i.e. AY 2013-14 to 2015-16 & 2017-18 are “unabated” ones; and, therefore, we hardly find any merit in the Revenue’s vehement contentions supporting the four impugned assessments, which are hereby quashed in very terms.
All other pleadings on merits between the parties herein stand rendered academic.
ITA No.534 to 537/Del/2025 &
605 to 607/Del/2025
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These assessee’s four appeals ITA Nos.534 to 537/Del/2025 are allowed and the Revenue’s three cross appeals ITA Nos.605, 606 & 607/Del/2025 are dismissed, in above terms. A copy of this common order be placed in the respective case files. Order pronounced in the open court on 6th & 13th August, 2025 (MANISH AGARWAL) JUDICIAL MEMBER
Dated: 6th & 13th August, 2025. RK/-