DANA ANAND INDIA PRIVATE LIMITED,PUNE V. DCIT, AKURDI,PUNE

ITA 1571/PUN/2024

AI Insights

The case involves Dana Anand India Pvt. Ltd., which appealed against the order of the Assessing Officer concerning the assessment year 2020-21. The primary issues in the appeal included the disallowance of deduction under section 80G for CSR expenditures, the addition under section 41(1) concerning amounts written off by vendors, and the adjustment of taxes against interest under section 115P. The Tribunal found merit in the assessee's arguments regarding the deduction under section 80G, aligning with precedents set by the Pune Bench in similar cases. The matter of the addition under section 41(1) and the tax adjustment issue were remanded back to the Assessing Officer for further examination and appropriate action.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 32450 (ITAT-PUNE)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 04-04-2025
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Assessment Year: 2020-2021
• Other Referred Cases: Advik Hi Tech (P.) Ltd. vs. DCIT, Credit Suisse Services (India) Private Limited vs. DCIT, Allegi Services (India) Pvt. Ltd. V. ACIT, Prabhavati S. Shah v. CIT
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: RAMNATH P MURKUNDE
• Assessee Lawyers: R D ONKAR; VARIOUS DECISIONS OF HONBLE
• Keywords: Set aside; Business income; Opportunity of being heard; Additional evidence; Transfer pricing; International transaction; Bad and doubtful debts; Deemed to accrue or arise in india; Charitable institution; Ineligible deduction
• Section: 143(3); 154; 143(1); 13; 37; 37(1); 80G

Judgement Text

"IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY BHAMORE, JUDICIAL MEMBER ITA No.1571/PUN/2024 Assessment year : 2020-21 Dana Anand India Pvt. Ltd. 29 Milestone, Pune Nashik Highway, Kuruli B.O., Kuruli – 410501 Maharashtra Vs. DCIT, Akurdi, Pune PAN: AAECS1869C (Appellant) (Respondent) Assessee by : Shri R D Onkar Department by : Shri Ramnath P Murkunde Date of hearing : 03-04-2025 Date of pronouncement : 04-04-2025 O R D E R PER R. K. PANDA, VP : This appeal filed by the assessee is directed against the order dated 13.06.2024 of the Assessing Officer passed u/s 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter referred to as „the Act‟) for assessment year 2020-21. 2. Facts of the case in brief, are that the assessee filed its original return of income on 26.05.2021 declaring total income of Rs.164,60,25,620/- which was revised by declaring total income of Rs.167,30,95,140/-. Since the assessee had undertaken certain international transactions, the Assessing Officer referred the matter to the Transfer Pricing Officer (TPO) for determination of the arm's length 2 ITA No.1571/PUN/2024 price of the international transactions who proposed Nil adjustment. However, the Assessing Officer took Rs.1,64,17,30,653/- as variation with respect to the TP adjustment. The Assessing Officer thereafter passed the draft assessment order determining the total income at Rs.338,51,08,520/- by making certain other additions. 3. The assessee approached the Dispute Resolution Panel (DRP) who deleted the TP adjustment of Rs.1,64,17,30,653/-. So far as the other additions made by the Assessing Officer in the draft assessment order are concerned, the DRP gave part relief to the assessee. The Assessing Officer accordingly passed the final order on 13.06.2024 determining the total income of the assessee at Rs.1,74,32,07,350/- by making the following additions: S No. Description Amount (in INR) 1 Income as per Return of income filed 167,30,95,140/- 2 Income as computed u/s143(1)(a) 171,08,51,010/- 3 Variation in respect of disallowance of deduction claimed u/s 80G of the Act 1,57,55,750/- 4 Addition u/s 41 of the Act 6,66,765/- 5 Education cess 1,59,33,528/- 6 Total variations made 3,23,56,340/- 7 Total Income 174,32,07,350/- 4. Subsequently, the Assessing Officer passed the order u/s 154 of the Act deleting certain additions. 5. Aggrieved with such order of the Assessing Officer/TPO/DRP, the assessee is in appeal before the Tribunal by raising the following grounds: 3 ITA No.1571/PUN/2024 On the facts and circumstances of the case and in law, I. Disallowance of Deduction w/s 80G of the Act 1. The learned AO erred in disallowing deduction claimed under section 80G amounting to Rs.1,57,55,750/- in respect of the donation to charitable institution registered u/s 80G. 2. The learned AO and DRP erred in not reckoning the legal principle that the provisions of section 37 and section 80G of the Act are independent and that the said donations have been already disallowed by the appellant in computing income from business as per the Explanation 2 to section 37(1) of the IT Act. The learned AO/ DRP failed to appreciate that the deduction u/'s 800 falling in Chapter VIA has been claimed by the appellant in respect of the amount donated voluntarily to the donee out of its own volition and benefit thereof has been claimed at the stage of computation of its total income as per the provisions of Section 80A of the Act. II. Disallowance under section 41(1) of the Act 3. The learned AO erred adding back an amount of Rs.6,66,765/- to the total income of the appellant, being the amounts written off by the vendor creditors unilaterally as so called 'bad debts' in their books of account. 4. The learned AO and DRP grossly erred in bringing to tax the amount of Rs. 6,66,765/- u/s 41(1) consisting of Rs.51,310/- on the ground that the GST invoices were available and details could have been accessed from GST network and the other amount of Rs.6,15,455/-on the ground that outstanding balance in the appellant's books in respect of the vendor was Rs.6,87,088/-. The learned AO and DRP failed to appreciate that the appellant had neither claimed the deduction of the said amounts nor accrued or incurred any debt/ liability thereof to pay the amounts to the vendors and information viz. on GST network or the outstanding balance did not substantiate or justify the unilateral decision of the vendor's to write off amount as so called bad debt. 5. The Ld. AO and DRP failed to appreciate that unilateral write off by the vendor of the appellant company does not ipso facto result in any benefit enduring in the hands of the appellant in respect of a trading liability and the provisions of Section 41 of the Act are not applicable. III. The learned AO/ DRP erred in declining to deal with the grievance of the appellant relating to the variations incorporated and effectively added in the recomputed total income in the draft assessment order pursuant to the variations made by the CPC at the time of processing of appellant's return of income. 4 ITA No.1571/PUN/2024 Learned DRP erred in not appreciating the fact that its jurisdiction very much pertained to looking into said variations which had crept in the draft assessment order by way of addition of total amount thereof to total income and the learned DRP had requisite powers to affirm, reduce or enhance the variations proposed in the draft order as per the provisions of Section 144C(8). IV. The learned AO erred in not allowing the credit of taxes (refund) adjusted against the interest charged us 115P of Rs.1,97,07,060/- The appellant craves leave to add to, alter, amend or withdraw the grounds of appeal. 6. The first issue raised by the assessee in grounds of appeal is regarding the disallowance of deduction u/s 80G of the Act qua the CSR expenditure of Rs.1,57,55,750/-. 7. After hearing both sides we find the assessee made CSR expenditure to the extent of Rs.1,57,55,750/- which was disallowed by him in the computation of income u/s 37(1) of the Act. However, the assessee claimed the same as deduction u/s 80G of the Act which was not allowed by the Assessing Officer and the DRP upheld the action of the Assessing Officer. 8. We find the Pune Bench of the Tribunal in the case of Advik Hi Tech (P.) Ltd. vs. DCIT (2024) 168 taxmann.com 587 (Pune-Trib.) has held that the deduction claimed by the assessee u/s 80G on account of Corporate Social Responsibility (CSR) deserves to be allowed. The relevant observations of the Tribunal read as under: 5 ITA No.1571/PUN/2024 “8. We have heard the Ld. Representatives of the parties and perused the records. The facts are not in dispute. We find that an identical issue came up for consideration before the Co-ordinate Bench of Pune Tribunal in the case of Credit Suisse Services (India) Private Limited (supra) wherein the Tribunal dismissed the appeal of the Revenue relying on the decision of the ITAT Bangalore in the case of Allegi Services (India) Pvt. Ltd. V. ACIT in ITA No. 1693/Bangalore/2019 wherein it was held that the assessee is entitled to claim deduction u/s 80G with respect to donations forming part of CSR expenses. The relevant observations and findings of the Coordinate Bench of Pune Tribunal in the case of Credit Suisse Services (India) Private Limited (supra) are as under : “3. Both the learned representatives next invited our attention to the CIT(A)'s impugned detailed discussion allowing the assessee‟s sec.80G deduction claim as under : “5. Decision I have carefully perused grounds of appeal, facts of the case, submissions made by the Appellant, assessment order and other evidences on records. 5.1. Ground 1 Vide this Ground, the Appellant has challenged action of the AO in making the disallowance of Rs.4,55,13,521/- u/s 80G with respect to the donations forming part of Corporate Social Responsibility („CSR‟). In this regard, the Appellant has submitted that : • The amount paid to various funds is without any consideration in return and is in the nature of irrevocable contribution. Thus, such contributions partake the character of donation • Since, all other requisite conditions under section 80G have been satisfied and not in dispute, the Appellant is eligible for deduction under section 80G of the Act. The institution to whom the Donations are made are duly registered under section 80G(5) of the Act • The CSR expenditure is not allowed only for the purpose of section 37 for computing business income. If such expenditure is otherwise allowable as deduction under other provisions of the Act, the same cannot be disturbed. • The donations/expenditure made by the Appellant is towards women empowerment, education, environmental research etc. and forms part of CSR expenditure as per Schedule VII of the Companies Act, 2013. • The legislature has restricted the benefit only in two specific cases being „Swachh Bharat Kosh‟ („SBK‟) and „Clean Ganga Fund‟ („CGF‟) as per subclause (iiihk) and (iiihl) of section 80G(2)(a) of the Act, thereby implying that CSR contribution to other eligible institution qualifies for 6 ITA No.1571/PUN/2024 deduction under section 80G of the Act. The Appellant has made CSR contribution to funds other than SBK and CGF, thus, claim under section 80G of the Act shall be allowed. • The said claim, as discussed above, is supported by the Explanatory Memorandum to Finance Bill 2014 with restriction placed only in relation to specified funds under section 80G, clarification issued by MCA and multiple favourable decisions. I have considered the submissions made by the Appellant. I find that the issue is covered in favour of the Appellant by various decisions of Hon‟ble Tribunals. I find that Hon‟ble ITAT Bangalore in the case of Allegi Services (India) Pvt Ltd vs ACIT, (ITA No.1693/Bangalore/2019) has decided this issue in favour of the assessee. Relevant part of the said decision is reproduced as under : “Brief facts of the case are as under: 2. Assessee is a company and filed its return of income on 30/11/2016 declaring income of Rs.73,44,38,310/-. The case was selected for scrutiny and notice under section 143 (2) and 142 (1) along with questionnaire was issued to assessee. In response to statutory notices, representative of assessee appeared before Ld.AO and filed requisite details as called for. 3. Ld.AO from the details furnished by assessee observed that assessee claimed deduction amounting to Rs.8,40,000/- under section 80 G of the Act, towards donation paid. Ld.AO was of the opinion that claim made under section 80 G of the Act, was not allowable as the amount was forming part of CSR expenses debited to profit and loss account. Ld.AO was of the opinion that donation made outside CSR expenses was only eligible to be claimed under section 80 G of the Act. ………………………… 14. In our view, expenditure incurred under section 30 to 36 are claimed while computing income under the head, „Income form Business and Profession”, where as monies spent under section 80G are claimed while computing „„Total Taxable income” in the hands of assessee. The point of claim under these provisions are different. 15. Further, intention of legislature is very clear and unambiguous, since expenditure incurred under section 30 to 36 are excluded from Explanation 2 to section 37(1) of the Act, they are specifically excluded in clarification issued. There is no restriction on an expenditure being claimed under above sections to be exempt, as long as it satisfies necessary conditions under section 30 to 36 of the Act, for computing income under the head, “Income from Business and Profession”. 7 ITA No.1571/PUN/2024 16. For claiming benefit under section 80G, deductions are considered at the stage of computing “Total taxable income”. Even if any payments under section 80G forms part of CSR payments ( keeping in mind ineligible deduction expressly provided u/s.80G), the same would already stand excluded while computing, Income under the head, “Income form Business and Profession\". The effect of such disallowance would lead to increase in Business income. Thereafter benefit accruing to assessee under Chapter VIA for computing “Total Taxable Income” cannot be denied to assessee, subject to fulfillment of necessary conditions therein. 17. We therefore do not agree with arguments advanced by Ld.Sr.DR. 18. In present facts of case, Ld.AR submitted that all payments forming part of CSR does not form part of profit and loss account for computing Income under the head, “Income from Business and Profession”. It has been submitted that some payments forming part of CSR were claimed as deduction under section 80G of the Act, for computing “Total taxable income”, which has been disallowed by authorities below. In our view, assessee cannot be denied the benefit of claim under Chapter VI A, which is considered for computing „Total Taxable Income”. If assessee is denied this benefit, merely because such payment forms part of CSR, would lead to double disallowance, which is not the intention of Legislature. 19. On the basis of above discussion, in our view, authorities below have erred in denying claim of assessee under section 80G of the Act. We also note that authorities below have not verified nature of payments qualifying exemption under section 80G of the Act and quantum of eligibility as per section 80G(1) of the Act. 20. Under such circumstances, we are remitting the issue back to Ld.AO for verifying conditions necessary to claim deduction under section 80G of the Act. Assessee is directed to file all requisite details in order to substantiate its claim before Ld.AO. Ld.AO is then directed to grant deduction to the extent of eligibility. Accordingly grounds raised by assessee stands allowed for statistical purposes. In the result appeal filed by assessee stands allowed.\" In view of the above facts and respectfully following the decision of Hon‟ble ITAT Bangalore in the case of Allegi Services (India) Pvt Ltd (supra), I am of the considered view that the appellant is entitled to claim deduction u/s 80G with respect to the donations forming part of CSR expenses. However, in this regard, I direct the AO to verify whether the Appellant satisfies the requisite conditions prescribed for deduction u/s 80G. In case it satisfies the conditions for deduction u/s 80G, the claim of Rs. 4,55,13,521/- has to be allowed. If found contrary, the stand of the AO 8 ITA No.1571/PUN/2024 stands confirmed. The AO is directed to give effect by passing a speaking order. The Appellant is directed to furnish all relevant details online before the AO for verification. Ground is, thus, allowed for statistical purpose.” 4. Mr. Murkunde vehemently argued in favour of the Revenue‟s pleadings that the Ld. CIT(A)'s herein has erred in law and on facts in accepting the assessee‟s sec.80G deduction claim of Rs.4,55,13,521/- qua “CSR expenditure” not exigible for relief u/sec.37 of the Act. 5. The assessee has drawn strong support from Ld. CIT(A)'s above extracted detailed discussion. 6. We have given our thoughtful consideration to the foregoing rival stands and find no merit in the Revenue‟s instant sole substantive grievance. Suffice to say, the Revenue‟s only argument is that once the impugned expenditure is not allowable u/sec.37 of the Act; the same is also not exigible to sec.80G deduction as well. We find no substance in Revenue‟s instant sole substantive grievance as the Ld. CIT(A)'s detailed discussion has considered a catena of case law of various judicial forums (supra) already accepting the very issue in assessee‟s favour and against the department. We thus adopt judicial consistency herein as well to uphold the Ld. CIT(A)'s detailed discussion accepting the assessee‟s sec.80G deduction claim. Rejected accordingly.” 9. Respectfully following the decision of the Co-ordinate Bench of Pune Tribunal in the case of Credit Suisse Services (India) Private Limited (supra) and in the absence of any contrary material brought on record by the Revenue to take a different view, we set aside the order of Ld. CIT(A) on the issue and allow the appeal of the assessee.” 9. Respectfully following the decision of the Co-ordinate Bench of the Tribunal in the case of Advik Hi Tech (P.) Ltd. vs. DCIT (supra) which in turn has followed the decision of the Tribunal in the case of DCIT Vs. Credit Suisse Services (India) Private Limited vide ITA No.44/PUN/2024 order dated 15.05.2024 for assessment year 2020-21 and in absence of any contrary material brought to our notice by the Ld. DR, we hold that the Assessing Officer is not justified in denying the claim of deduction u/s 80G of the Act. We, therefore, direct the Assessing Officer to allow the benefit of deduction u/s 80G of the Act. 9 ITA No.1571/PUN/2024 The first issue raised by the assessee in the grounds of appeal is accordingly allowed. 10. The second issue raised by the assessee in the grounds of appeal is regarding the addition u/s 41(1) of the Act of Rs.6,66,765/- being unilaterally written off by the vendors viz. Goldy Precision Stamping Pvt. Ltd. of Rs.51,310/- and Nidec India P. Ltd. of Rs.6,15,454/-. 11. Facts of the case, in brief, are that the Assessing Officer, during the course of assessment proceedings, asked the assessee to provide the reasons for not showing the debt of company u/s 141 of the IT Act which has been written off by the creditors. The assessee submitted that the company has not written back any liability liable for taxability u/s 41 of the Act. He, therefore, issued a show cause notice proposing the addition of Rs.8,37,379/- since the assessee has not shown deemed income u/s 41 of the Act in respect of three parties, the details of which are as under: AABCG1087B Goldy Precision Stampings Pvt. Ltd. 51310/- AAACS5081L Nidec India Precision Tools Ltd. 615455/- APEPS5336Q Radhakrishna Shetty 170614 TOTAL 8,37,379/- 12. After considering the reply of the assessee, the Assessing Officer made addition of Rs.8,37,379/- u/s 41(1) of the Act. The DRP after considering the reply of the assessee restricted the addition to Rs.6,66,765/- in respect of two parties i.e. 10 ITA No.1571/PUN/2024 Goldy Precision Stamping Pvt. Ltd. of Rs.51,310/- and Nidec India P. Ltd. of Rs.6,15,455/-. 13. Before the Tribunal the assessee filed an application seeking permission of the Bench to admit certain additional evidences which read as under: \"II Disallowance under section 41(1) of the Act 3. The learned AO erred adding back an amount of Rs. 6,66,765/- to the total income of the appellant, being the amounts written off by the vendor creditors unilaterally as so called 'bad debts' in their books of account. 4. The learned AO and DRP grossly erred in bringing to tax the amount of Rs. 6,66,765/-u/s 41(1) consisting of Rs. 51,310/- on the ground that the GST invoices were available and details could have been accessed from GST network and the other amount of Rs. 6,15,455/- on the ground that outstanding balance in the appellant's books in respect of the vendor was Rs. 6,87,088/-. The learned AO and DRP failed to appreciate that the appellant had neither claimed the deduction of the said amounts nor accrued or incurred any debt/ liability thereof to pay the amounts to the vendors and information viz. on GST network or the outstanding balance did not substantiate or justify the unilateral decision of the vendor/s to write off amount as so called bad debt. 5. The Ld. AO and DRP failed to appreciate that unilateral write off by the vendor of the appellant company does not ipso facto result in any benefit enduring in the hands of the appellant in respect of a trading liability and the provisions of Section 41 of the Act are not applicable.\" Our Prayer 1. Subsequent to the passing of the assessment order dated 13.06.2024, Goldy Precision Stamping P Ltd. (GSP) vide its letter dated 3.10.2024 confirmed that the goods invoiced were not delivered to the appellant as the goods were lost in transit and the debit balance was written off in its books of account. Another creditor NIPL has vide its letter received by the appellant dated 29.08.2024 confirmed that the so called debits in its books of account were time worn debits coming from accounts of its predecessor company viz. erstwhile Mitsubishi Heavy Industries India Precision Tools Ltd. whose 11 ITA No.1571/PUN/2024 business was taken over by NIPL during the financial year ended 31st March 2019. Since the old debit entries brought forward in NIPL's books were lying in the accounts for more than 8 years it was not possible for NIPL to establish an audit trail as to whether the debits to appellant's account had arisen against supply of goods and whether the debits appearing had continued to appear as unpaid/ unadjusted due to rejection of goods or cancellation/adjustment of invoices and to clean up the accounts the said party unilaterally wrote off the amounts debited. It is submitted that both the parties after continuous follow up gave the aforesaid signed confirmations voluntarily and it was not in the hands of the appellant to make them available before the passing of finalized assessment order. The appellant submits that it was prevented by sufficient cause from producing the said supporting document/paper before the AO prior to his passing of finalized assessment order. 2. The aforesaid crucial confirmations received from the concerned vendors go to the root of the matter and clearly establish the authenticity and genuineness of appellant's claim that the amounts were unilaterally written off by the parties without accrual of any benefit enduring in appellant's hands as contemplated u/s 41 (1) of the Act. 3. Useful reference can be made in this regard to the decision of jurisdictional Bombay High Court in Prabhavati S. Shah v. CIT 231 ITR 0001 wherein Honourable High Court has held that information prima facie necessary and which would facilitate the judicial authority to decide the controversy in regard to the genuineness of the claim be permitted to be admitted. In the light of the aforesaid facts and attendant circumstances and judicial precedent it is prayed that the above referred confirmations of creditors be permitted to be adduced to facilitate the appellant to place its case before Your Honours.” 14. He submitted that since the above details go to the root of the matter for deciding the issue, therefore, these additional evidences should be admitted and a proper decision may be taken. 15. The Ld. DR on the other hand opposed the admission of the additional evidences. In his alternate contention, he submitted that the matter may be restored 12 ITA No.1571/PUN/2024 to the file of the Assessing Officer with a direction to verify the same and take a view. 16. After hearing both sides we find the additional evidences filed by the assessee go to the root of the matter. We, therefore, admit the same and restore the matter to the file of the Assessing Officer with a direction to verify the same and pass an appropriate order as per fact and law after giving due opportunity of being heard to the assessee. We hold and direct accordingly. The second issue raised by the assessee is accordingly allowed for statistical purposes. 17. The third issue raised by the assessee relates to the order of the DRP in not adjudicating on the variation made by the CPC vide Intimation u/s 143(1) of the Act and which ultimately culminated in and merged into the addition to total income determined in order u/s 143(3) r.w.s. 144C(13) of the Act pursuant to the DRP directions. 18. The Ld. Counsel for the assessee submitted that the assessee has got the due benefit from the Assessing Officer and therefore, this ground has become academic in nature. In absence of any objection from the side of the Ld. DR and considering the fact that the assessee has already got the due relief, this ground has become academic in nature. In view of the above and considering the fact the Ld. Counsel 13 ITA No.1571/PUN/2024 for the assessee has not pressed this ground, therefore, the same is dismissed as “not pressed”. 19. The fourth issue raised by the assessee in the grounds of appeal relates to the non allowing credit of taxes adjusted against the interest charged u/s 115P of the Act of Rs.1,97,07,060/-. 20. The Ld. Counsel for the assessee submitted that the DRP has directed the Assessing Officer to consider the claim for credit of DDT and allow credit as per law. The Assessing Officer in the final order on the basis of directions of the DRP allowed the claim of the assessee and allowed credit of DDT paid. However, since the interest charged allegedly for non-payment of DDT has not been deleted and raised the demand of tax erroneously in the final order, the Ld. Counsel for the assessee submitted that the same may be deleted. 21. The Ld. DR on the other hand submitted that the matter may be restored to the file of the Assessing Officer to pass necessary order on this issue. 22. After hearing both sides, we deem it proper to restore this issue to the file of the Assessing Officer with a direction to verify the record and rectify the demand of tax after providing due opportunity of being heard to the assessee. The fourth issue raised by the assessee is accordingly allowed for statistical purposes. 14 ITA No.1571/PUN/2024 23. In the result, the appeal filed by the assessee is partly allowed for statistical purposes. Order pronounced in the open Court on 4th April, 2025. Sd/- Sd/- (VINAY BHAMORE) (R. K. PANDA) JUDICIAL MEMBER VICE PRESIDENT पुणे Pune; दिन ांक Dated : 4th April, 2025 GCVSR आदेश की प्रतितिति अग्रेतिि/Copy of the Order is forwarded to: 1. अपीलार्थी / The Appellant; 2. प्रत्यर्थी / The Respondent 3. 4. The concerned Pr.CIT, Pune DR, ITAT, „A‟ Bench, Pune 5. गार्ड फाईल / Guard file. आदेशानुसार/ BY ORDER, // True Copy // Senior Private Secretary आयकर अपीलीय अधिकरण ,पुणे / ITAT, Pune S.No. Details Date Initials Designation 1 Draft dictated on 03.04.2025 Sr. PS/PS 2 Draft placed before author 04.04.2025 Sr. PS/PS 3 Draft proposed & placed before the Second Member JM/AM 4 Draft discussed/approved by Second Member AM/AM 5 Approved Draft comes to the Sr. PS/PS Sr. PS/PS 6 Kept for pronouncement on Sr. PS/PS 7 Date of uploading of Order Sr. PS/PS 8 File sent to Bench Clerk Sr. PS/PS 9 Date on which the file goes to the Head Clerk 10 Date on which file goes to the A.R. 11 Date of Dispatch of order "