Non-application of mind in appellate orders due to reliance on another entity's facts vitiates the order and mandates fresh adjudication.

Appellate order reproduced facts and figures belonging to a different legal entity, demonstrating non-application of mind; an appellate authority must decide appeals on correct and relevant material pertaining to the specific appellant, and reliance on another assessee's records invalidates conclusions drawn. Post-facto explanations or pending rectification cannot cure an order founded on erroneous factual foundations. Consequentially, the impugned order was set aside and the matters remitted to the appellate file for fresh adjudication after consideration of correct facts and material.

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Issues: Whether the appellate order dated 16.07.2025 passed by the Learned Addl./JCIT(A) is vitiated by non-application of mind because it incorporates facts, figures and observations pertaining to a different legal entity (Novartis Healthcare Private Limited) instead of the present assessee (Novartis India Limited), and whether the impugned order should be set aside and the matters restored to the file of the Ld. CIT(A) for fresh adjudication.

Analysis: The impugned appellate order reproduced the statement of facts, extracts of the assessment order, and figures of additions that belong to a distinct legal entity rather than the assessee before the appellate authority. An appellate authority must adjudicate on the basis of correct and relevant facts and material pertaining to the party whose appeal is under consideration. Reliance on factual material of a different assessee demonstrates lack of application of mind and undermines the validity of the conclusions drawn. Post-facto explanations or the pendency of rectification applications cannot cure an order founded on an erroneous factual foundation. Given that the foundational facts were incorrect, the appellate conclusions based on those facts cannot stand and require fresh adjudication by the appellate authority after consideration of correct records.

Conclusion: The impugned order is vitiated by non-application of mind and is set aside. The appeal filed by the Revenue and the cross-objection filed by the assessee are allowed for statistical purposes and the matters are restored to the file of the Learned CIT(A) for fresh adjudication strictly in accordance with law after considering correct facts and material.

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