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2026 (9) TMI 1179

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.... J. (ORAL) 1. These appeals portray a rather shocking picture of the procedural lapses and opaqueness in which the Income Tax Appellate Tribunal (hereinafter referred to as 'the Tribunal'), the highest fact-finding body, has been passing the orders in a zeal rather over-anxiety of disposing the cases. In the order under consideration, where the learned Members of the Tribunal have neither dealt with any contention of the assessee nor have, they discussed the issues involved in the appeals and disposed of seven appeals, vide an order which does not even contain seven paragraphs. 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....

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....n perusal of the impugned order, we are unable to comprehend anything out of it, as it is bereft of any logic, reasoning or rationale behind it. Apart from the procedural lacuna, we fail to understand that how a common order can be passed and released in relation to four appeals, which were heard and qua which the order was pronounced on 06.08.2025, whereas other three appeals were heard and order was pronounced on 13.08.2025. 7. It is therefore, clear that the learned Members have shown undue haste rather recklessness while passing and signing the order, and even their staff failed to bring it to notice of the learned Members while getting the order signed. Such type of negligence cannot be countenanced. The Appellate Authorities, who a....

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....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 BuildwellPvt. 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 a....