PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI vs. PATANJALI AYURVED LIMITED

ITA - 250 / 2025HC Delhi28 July 20252 pages

For Petitioner: PUNEET RAI

AI SummaryPartly Allowed

What did the High Court hold?

The High Court has not adjudicated on the merits of the ITAT's order. The Court has primarily dealt with the procedural aspects of the appeal. Firstly, it has condoned the delay of 44 days in filing the appeal by the Revenue, accepting the reasons provided in the application. Secondly, it has allowed the exemption application, subject to all just exceptions. The substantive part of the judgment involves issuing notice to the respondent (assessee) through all permissible modes, returnable on 10.11.2025. This indicates that the appeal is admitted for further hearing on its merits. No finding has been made on any specific issue decided by the ITAT, nor has any ratio decidendi been established regarding the substantive tax dispute.

What were the facts?

The Pr. Commissioner of Income Tax, Central-1, Delhi (the Revenue) has filed an appeal under Section 260A of the Income Tax Act, 1961, challenging an order dated 27.12.2024 passed by the Income Tax Appellate Tribunal (ITAT). The ITAT's order pertains to ITA No.1989/Del/2020 and Cross Objection No.84/Del/2023 concerning Assessment Year 2011-12. The appeal was filed with a delay of 44 days, for which an application for condonation was filed and allowed. The respondent, Patanjali Ayurved Limited (the assessee), was not represented. The High Court has issued notice to the respondent, returnable on 10.11.2025.

What were the issues?

The primary question before the High Court is: 1. Whether the High Court should entertain the appeal filed by the Revenue against the order of the ITAT dated 27.12.2024 concerning AY 2011-12, given the delay in filing and the absence of the respondent. The Revenue's contention, implied by the filing of the appeal, is that the ITAT's order is erroneous and requires judicial review. The judgment does not record any specific arguments from the Revenue regarding the merits of the ITAT's decision. The respondent (assessee) has not made any submissions as they were not represented before the High Court.

Which sections of the Income-tax Act were involved?

Section 260A

AI-generated summary — verify with the full judgment below

$~55 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 250/2025

PR. COMMISSIONER OF INCOME TAX, CENTRAL-1, DELHI .....Appellant Through: Mr Puneet Rai, Sr Standing Counsel, Mr Ashvini Kumar, Mr Rishabh Nangia and Mr Girban Naushad, Standing Counsels.

versus

PATANJALI AYURVED LIMITED .....Respondent

Through: None.

CORAM:

HON'BLE MR. JUSTICE V. KAMESWAR RAO

HON'BLE MR. JUSTICE VINOD KUMAR

O R D E R %

28.07.2025 CM APPL. 45289/2025 (condn of delay in filing) 1. For the reasons stated in the application, the delay of 44 days in filing captioned appeal is condoned. 2. The application stands disposed of. CM APPL. 45288/2025(Exemption) 3. Exemption is allowed, subject to all just exceptions. 4. The application stands disposed of. ITA 250/2025 5. The challenge in this appeal under Section 260A of the Income Tax Act, 1961 (the Act) is to the order dated 27.12.2024 passed by the Income Tax Appellate Tribunal (the ITAT) in ITA No.1989/Del/2020 and Cross This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 12:49:54

Objection No.84/Del/2023 in respect of the Assessment Year (AY) 2011-12. 6. Issue notice to the respondent through all permissible modes returnable on 10.11.2025.

V. KAMESWAR RAO, J

VINOD KUMAR, J JULY 28, 2025 M This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 12:49:54

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