DCIT CIRCLE 4(1)(1), AHMEDABAD, AHMEDABAD V. SUKHAM PROPERTIES PRIVATE LIMITED, AHMEDABAD

ITA 607/AHD/2024

AI Insights

The case involves the Deputy Commissioner of Income Tax (DCIT), Circle-4(1)(1), Ahmedabad, as the appellant, and Sukham Properties Pvt. Ltd. as the respondent. The appeal by the Revenue challenged the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, which had deleted the additions made by the Assessing Officer under sections 69A and 68 of the Income Tax Act, 1961, for the Assessment Year 2020-21. The additions pertained to unexplained money and unsecured loans, respectively. The Tribunal's decision focused on the procedural and substantive aspects of the additions and the adequacy of evidence provided by the assessee.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 29628 (ITAT-AHMEDABAD)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 26-03-2025
• Appeal Filed By: Department
• Order Result: Partly Allowed
• Bench Allotted: C
• Assessment Year: 2020-2021
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: RIGNESH DAS
• Assessee Lawyers: PRITESH L. SHAH
• Keywords: Set aside; Corroborative evidences; Unexplained cash credit; TDS; Source of fund; Initiation of penalty proceedings; FORM 26AS
• Section: 143(3); 133(6); 13; 69A; 115JB

Judgement Text

" आयकर अपीलीय अिधकरण, अहमदा बा द \u0012ा यपीठ “सी“, अहमदा बा द । IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD सु\u0017ी सुिच\u0019ा का \u001aले, \u0012ा ियक सद एवं \u0017ी मकरंद वसंत महा देवकर, लेखा सद क े सम\"। ] ] BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER आयकर अपील सं /ITA No.607/Ahd/2024 िनधा \u0010रण वष\u0010 /Assessment Year : 2020-21 DCIT Circle-4(1)(1) Ahmedabad बनाम/ v/s. Sukham Properties Pvt.Ltd. 101, Devarc Mall Ahmedabad City Jodhpur Char Rasta SO Ahmedabad – 380 015 \u0014थायी लेखा सं./PAN: AAQCS 3397 D अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee by : Shri Pritesh L. Shah, AR Revenue by : Shri Rignesh Das, Sr.DR सुनवाई की तारीख/Date of Hearing : 24 /03/2025 घोषणा की तारीख /Date of Pronouncement: 26 /03/2025 आदेश/O R D E R PER MAKARAND V. MAHADEOKAR, AM: This appeal by the Revenue is directed against the order dated 05.02.2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, [hereinafter referred to as “CIT(A)”] for the Assessment Year (AY) 2020–21, whereby the Ld. CIT(A) deleted the additions made by the Assessing Officer [hereinafter referred to as “AO”] under sections 69A and 68 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”]. ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 2 Facts of the Case: 2. The assessee is a Private Limited Company engaged in the business of land and property transactions. It filed its return of income for A.Y. 2020–21 on 08.12.2020, declaring a total income of Rs.53,10,650/- under the normal provisions and Rs.1,02,08,725/- under section 115JB of the Act. The case was selected for limited scrutiny under CASS for the issues of High Creditors / Liabilities, and Unsecured Loans. 3. During the course of assessment proceedings, the AO noted that the assessee had credited a sum of Rs.1,00,00,000/- to its Profit and Loss account under the head “Other Income,” with the narration indicating that the amount represented an advance received against a property that had been forfeited. On further inquiry, it was revealed that no agreement for sale or cancellation was available for verification. The note appended to the financial statements explicitly recorded that the amount was subject to confirmation from the concerned party. The AO, in order to verify the genuineness of this transaction, called upon the assessee to furnish the agreement to sell, the cancellation agreement, confirmation from the party, and supporting documentary evidence. The assessee admitted that the relevant file had been misplaced and was therefore unable to produce any supporting evidence, including the identity or PAN of the counterparty. In the absence of any documentary evidence to substantiate the claim, the AO held that the nature and source of the said sum remained unexplained. Accordingly, the amount of Rs.1 crore was treated as unexplained money under section 69A of the Act and brought to tax under the provisions of section 115BBE of the Act. 3.1. In respect of unsecured loans aggregating to Rs.6.54 crores, the AO particularly examined loans amounting to Rs.4.07 crores, claimed to have ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 3 been received from three entities—Origin Lifecare Pvt. Ltd. (Rs.2.02 crore), Fringe Properties Pvt. Ltd. (Rs.2.03 crore), and Opus Restaurants Pvt. Ltd. (Rs.2 lakh). The AO called for confirmations and documentary support from the assessee. On verification, it was found that Origin Lifecare Pvt. Ltd. was a company that had been struck off by the Registrar of Companies. Further, it was noted that prior to disbursement of the loan, the lender had a negligible bank balance and had received an equivalent sum from Satyam Corporation on the same day, which was immediately routed to the assessee. The AO concluded that the transaction was circular in nature and lacked commercial substance. No response was received to the notice issued u/s 133(6) of the Act, to the lender. Accordingly, in the AO’s view, the assessee failed to prove the identity, creditworthiness, and genuineness of the transaction. The amount of Rs.2.02 crore was therefore added to the total income of the assessee under section 68, read with section 115BBE of the Act. 3.2. Similarly, in the case of Fringe Properties Pvt. Ltd., it was observed that the lender shared the same address as Origin Lifecare Pvt. Ltd. and also exhibited a pattern of immediately receiving funds from other entities— namely, Articulate and Rudra Global Infra—before extending the loans to the assessee. On 09.09.2019, the lender had a bank balance of merely Rs.54,273/- and thereafter received substantial sums shortly before transferring Rs.1 crore to the assessee on 24.09.2019 and another Rs.1 crore on 29.11.2019. These transactions, according to the AO, were indicative of a pre-meditated scheme to route unaccounted money into the books of the assessee. The lender did not respond to the notice issued under section 133(6) of the Act, and it was further noted that the lender had declared nil income in the preceding years and incurred a loss of Rs.36,99,425/- in A.Y. 2020–21. The AO concluded that the assessee failed to discharge the primary onus cast upon it under section ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 4 68. Consequently, an addition of Rs.2.03 crore was made under section 68, read with section 115BBE of the Act. 3.3. As regards the unsecured loan of Rs.2 lakh received from Opus Restaurants Pvt. Ltd., the assessee failed to furnish even the basic particulars such as PAN, bank statement, or confirmation from the lender. In the absence of any supporting evidence, the AO disbelieved the transaction and added the amount of Rs.2,00,000/- under section 68, treating it as unexplained cash credit. 3.4. Accordingly, the AO concluded the assessment by making a total addition of Rs.5,07,00,000/-, comprising Rs.1 crore under section 69A of the Act and Rs.4.07 crore under section 68 of the Act, resulting in the determination of total income at Rs.5,60,10,650/- as against the returned income of Rs.53,10,650/-. Penalty proceedings u/s 271AAC(1) of the Act were also initiated in respect of the additions so made. 4. In the appellate proceedings before the Ld. CIT(A), the assessee challenged the assessment order passed under section 143(3) read with section 144B of the Act. The grounds raised before the CIT(A) pertained primarily to the addition of Rs.1,00,00,000/- made under section 69A of the Act on account of forfeited advance, and Rs.4,07,00,000/- made under section 68 of the Act in respect of unsecured loans received from three parties, namely, Origin Lifecare Pvt. Ltd., Fringe Properties Pvt. Ltd., and Opus Restaurants Pvt. Ltd. The assessee also challenged the initiation of penalty proceedings under section 271AAC(1) of the Act. ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 5 4.1. The Ld. CIT(A) noted that the case was selected for limited scrutiny and, therefore, the addition of Rs.1,00,00,000/- made by the AO were outside the scope of limited scrutiny. The CIT(A) deleted the addition. 4.2. Regarding the additions of unsecured loans u/s 68 of the Act, during the appellate proceedings, the assessee filed a detailed submission refuting the observations of the AO. It was contended that all documentary evidence—PAN, bank statements, confirmations, and Income Tax Returns of the lenders—were submitted. The appellant argued that all three companies were registered entities under the Companies Act and the loans were genuine inter-corporate deposits. It was further submitted that the loans were largely repaid within the same or subsequent assessment year, indicating commercial substance. Regarding the timing of credits, the assessee argued that prudent business practice does not require maintaining idle balances and short-term fund inflows are commercially normal. On the issue of loss returns filed by the lenders, the assessee submitted that business losses do not indicate lack of credibility or inability to lend. The CIT(A), after considering the assessee's submissions and documents, proceeded to examine the ledger accounts and repayment pattern in respect of each lender. In case of unsecured loan from M/s. Origin Lifecare Pvt. Ltd. amounting to Rs.2.02 crore, it was noted that the assessee had received loans through banking channels, and the AO himself had tabulated the inflow of funds from third parties into this entity. The CIT(A) observed that the ledger account showed substantial repayments before 31.03.2022, and the balance amount of Rs.67,57,354/- was repaid by 27.09.2022. Thus, identity, creditworthiness, and genuineness of the transaction stood established. Accordingly, the CIT(A) directed deletion of the addition of Rs.2,02,00,000/-. ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 6 4.3. Similar findings were recorded in respect of unsecured loan from M/s. Fringe Properties Pvt. Ltd. amounting to Rs.2.03 Cr. The AO had noted in the assessment order that this company too had borrowed funds from other entities before granting the loan to the assessee. The ledger account indicated that it was a running account from 27.03.2019 and that the entire outstanding loan of Rs.2.03 crore as on 31.03.2020 was fully repaid by 11.02.2021. Therefore, the CIT(A) held that the three requisite conditions of section 68 of the Act—identity, creditworthiness, and genuineness—were duly satisfied. Consequently, the AO was directed to delete the addition of Rs.2,03,00,000/-. 4.4. In respect of unsecured loan of Rs.2 lakh from M/s. Opus Restaurants Pvt. Ltd., the assessee failed to furnish documentary evidence such as the PAN, bank statement, or income tax details of the lender. The only document submitted was the ledger account of the appellant, which showed that the amount of Rs.2 lakh was received on 08.08.2019 and unilaterally written off by the assessee on 01.04.2023, being treated as “not payable as further advances not received.” The CIT(A) held that the assessee had failed to discharge the onus cast under section 68 to prove identity, creditworthiness, and genuineness. Accordingly, the addition of Rs.2,00,000/- under section 68 of the Act was upheld. 5. Aggrieved by the order of the CIT(A), the Revenue preferred the present appeal before us raising following grounds of appeal: “(a) The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs.1,00,00,000/- made by the Assessing Officer on account of unexplained money under section 69A of the Income Tax Act. ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 7 (b) The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs.4,05,00,000/- made by the Assessing Officer on account of unsecured loans under section 68 of the Income Tax Act. (c) The appellant craves leave to add, alter and/or amend any of the grounds before the final hearing of the appeal.” On Ground No. 1 relating to addition of Rs.1,00,00,000/- u/s 69A of the Act. 6. During the course of hearing before us, the Learned Departmental Representative (DR) submitted that the Commissioner of Income Tax (Appeals) erred in deleting the addition of Rs.1,00,00,000/- made by the AO under section 69A of the Act solely on the ground that the issue was outside the scope of limited scrutiny. It was contended that the CIT(A) granted relief without examining the merits of the addition, and that such a course of action was not justified. The DR urged that the matter be restored for adjudication on merits. 7. The Learned Authorized Representative (AR), on the other hand, submitted that the amount of Rs.1,00,00,000/- in question represented an advance received from Som Shiva Impex Ltd. towards a proposed sale transaction of property, which was subsequently forfeited due to non- fulfilment of contractual terms. It was submitted that the said amount was credited to the Profit and Loss account under the head “Other Income” and duly offered to tax under the head “Income from Other Sources” in the return of income filed by the assessee. The AR clarified that although the agreement for sale and its cancellation deed could not be produced due to misplacement of the relevant file, this fact had been duly recorded in the statutory audit report annexed to the return of income. In support of the transaction, the assessee had disclosed the name and address of the counterparty and brought to the notice of the authorities that TDS of Rs.1,00,000/- had been deducted ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 8 on the said amount by Som Shiva Impex Ltd., and the same was reflected in Form 26AS and claimed in the return. It was thus submitted that the transaction was a disclosed and offered as income, and therefore, the provisions of section 69A of the Act could not be invoked in the absence of any unexplained or undisclosed element. The AR further contended that bringing the same amount to tax again under section 69A of the Act would amount to double taxation, which is not permissible under the scheme of the Act. 8. We have carefully considered the rival submissions and perused the material available on record. The primary basis on which the Ld. CIT(A) deleted the addition of Rs.1,00,00,000/- made by the AO under section 69A of the Act was that the issue did not fall within the limited scrutiny parameters. It is well settled that even in limited scrutiny assessments, additions beyond the selected issue may be made provided the AO follows the prescribed procedure and obtains necessary administrative approval. However, in the present case, we find that the assessee had credited the said amount to the Profit and Loss account under the head \"Other Income\" and had also offered the same to tax under the head “Income from Other Sources” in the return of income. The statutory audit report clearly recorded the fact that the agreement in support of the forfeited advance was not traceable. The assessee furnished the name and address of the party, i.e., Som Shiva Impex Ltd., and it is an undisputed fact on record that TDS of Rs.1,00,000/- had been deducted on the said amount, as reflected in Form 26AS. The Revenue has not disputed that the amount has already been taxed under the normal provisions. ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 9 8.1. In view of the above facts, we are of the considered opinion that once the amount has been duly offered to tax by the assessee and is reflected in the audited books of account and return of income, there was no justification for invoking section 69A of the Act. The addition made by the AO, in effect, amounts to taxing the same amount twice, which is not permissible under the law. Although the Ld. CIT(A) has deleted the addition primarily on the ground of jurisdictional limitation in a limited scrutiny case, we are inclined to uphold the deletion on the merits of the case, as the amount stands fully disclosed and taxed. Accordingly, we do not find any infirmity in the action of the Ld. CIT(A) in deleting the addition, though for reasons different than those recorded by him. 8.2. We, therefore, confirm the deletion of the addition of Rs.1,00,00,000/- made under section 69A of the Act. Ground No. 1 raised by the Revenue is, therefore, dismissed. On Ground No. 2 relating to addition of Rs.4,05,00,000/- u/s 68 of the Act. 9. In respect of Ground No. 2, the Learned DR primarily relied upon the findings recorded by the AO and submitted that the Ld. CIT(A) erred in deleting the addition of Rs.4,05,00,000/- made under section 68 of the Act in respect of unsecured loans received from M/s. Origin Lifecare Pvt. Ltd. and M/s. Fringe Properties Pvt. Ltd. The DR pointed out that both these companies were found to be struck off by the Registrar of Companies, which casts serious doubt on the genuineness of the transactions. It was further submitted that notices issued under section 133(6) of the Act to the concerned lenders remained unanswered, and therefore, no independent verification of the identity, creditworthiness, or genuineness of the loan transactions could ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 10 be carried out. The DR also highlighted that both the entities had incurred losses in the relevant and earlier years, and hence the claim that such companies were in a financial position to extend substantial loans could not be accepted at face value. Accordingly, it was argued that the Ld. CIT(A) failed to appreciate these material aspects while granting relief to the assessee, and the deletion of the additions made by the AO was not justified. 10. The Learned AR, in response, submitted that the assessee had duly discharged the initial onus cast under section 68 of the Act by furnishing complete details in respect of the unsecured loans, including the names, PANs, confirmations, bank statements, and financial records of the lending companies. It was further submitted that the identity of the lenders was not in dispute, and even the source of source of funds had been disclosed in the course of assessment proceedings. The AR emphasized that both the lending companies—M/s. Origin Lifecare Pvt. Ltd. and M/s. Fringe Properties Pvt. Ltd.—had advanced the amounts through regular banking channels, and the transactions were duly recorded in the books of account. 10.1. The AR further pointed out that the loans were not only genuine but also stood fully repaid in subsequent financial years, which substantiated the genuineness and commercial nature of the transactions. The AR pointed out at the copies of ledger account extracts of the lenders in the books of assessee. In the case of Origin Lifecare Pvt. Ltd., it was submitted that a substantial portion of the loan had been repaid by 31.03.2022 and the remaining by 27.09.2022. Similarly, the loan from Fringe Properties Pvt. Ltd. was fully repaid by 11.02.2021. The AR also pointed out the bank statements of the lenders and explained the repayment. The AR contended that merely because the lender companies had incurred losses or were later struck off by the ROC, ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 11 the genuineness of the loan transactions could not be doubted, particularly when all material particulars and documentation had been placed on record and remained uncontroverted. It was thus submitted that the Ld. CIT(A) had rightly deleted the additions after proper appreciation of facts and evidence. Upon careful examination of the records and submissions, we note that the assessee had claimed to have received a loan of Rs. 2,02,00,000/- from M/s. Origin Lifecare Pvt. Ltd. during the year under consideration. It is not in dispute that the said company was struck off by the Registrar of Companies, however, the exact date of such striking off was not clarified either by the Learned Departmental Representative (DR) or the Learned Authorised Representative (AR). Notably, it was observed during the course of hearing that the bank account of the said company continued to be operative even after its name was struck off, a fact which raises serious concerns regarding the legal capacity of the company to transact after being struck off. Despite being specifically asked, neither the DR nor the AR could provide a satisfactory explanation as to how a company that has been struck off under the Companies Act could legally operate a bank account and carry out financial transactions. We further observe that while the assessee claimed to have repaid the said loan partly through RTGS and partly by way of cheques, the bank statements of Origin Lifecare Pvt. Ltd. available on record do not conclusively demonstrate such repayments, particularly repayments by cheques. The AR himself admitted that he was unable to confirm the repayment in absence of the complete bank statement of the lender. It was also noticed from the bank account furnished that the pattern of transactions showed a one-to-one correlation between deposits and immediate payments, indicating a lack of independent creditworthiness or own funds with the lender. These features cast doubt on the genuineness and veracity of the entire loan transaction. ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 12 11. In our considered view, these aspects—particularly the factum of actual repayment of the loan, the operational status and legal existence of the lender, and the nature of fund flow in the lender’s bank account—are critical for determining whether the assessee has satisfactorily discharged the burden under section 68 of the Act. We find that the Ld. CIT(A) has not addressed these material aspects and proceeded to allow relief without proper verification. Therefore, we are of the opinion that the matter, insofar as the loan from Origin Lifecare Pvt. Ltd. is concerned, requires proper factual verification by the AO. 11.1. Insofar as the loan transaction with Fringe Properties Pvt. Ltd. is concerned, we note that during the course of assessment proceedings, the assessee had submitted that the transaction was genuine, and that the creditworthiness of the lender stood established on the basis that the payment was made through inter-corporate deposit via banking channels. It was further submitted that the bank statement of the lender contained multiple entries reflecting its own source of funds, and that the specific credits made to the assessee had been highlighted by colour marking for ease of identification. However, upon perusal of the bank statement of the said lender, we observe that the bank account was opened only on 22.07.2019 with an initial cash deposit of Rs.5,000/-, and thereafter, the account reflects only large-value receipts and immediate payments, with no discernible pattern indicating sustained operations or independent fund capacity. The pattern of transactions gives rise to a prima facie inference that the funds may have been routed through the lender, rather than originating from its own established resources. Contrary to the assessee’s submission during the assessment proceedings, there is no clarity or supporting material to demonstrate that the lender had its own accumulated or operational funds capable of justifying ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 13 the advance of a substantial loan amount of Rs.2.03 crore. The source of funds received by the lender also does not appear to be independently explained beyond indicating the immediate inflow and outflow. This raises questions as to the actual creditworthiness of the lender and whether the lender acted as a mere conduit. We further note that the Ld. CIT(A) accepted the genuineness of the transaction primarily on the basis of repayment made in the subsequent year and without examining the underlying financial strength and banking pattern of the lender. In our considered view, the source of funds of the lender, the nature of transactions in its bank account, and its financial ability to extend such a large loan are crucial aspects that need to be independently verified before granting relief under section 68 of the Act. 11.2. In light of the foregoing discussion, we are of the considered opinion that the issues relating to the unsecured loans received from Origin Lifecare Pvt. Ltd. and Fringe Properties Pvt. Ltd., aggregating to Rs.4,05,00,000/-, require fresh verification by the AO. In both cases, there are material concerns regarding the actual repayment of the loans, the operational and legal status of the lender companies, and the creditworthiness of the lenders at the time of advancing the loans. The nature and pattern of transactions reflected in the bank statements also warrant closer scrutiny. The Ld. CIT(A), while granting relief, did not address these key aspects. 11.3. Accordingly, we set aside the order of the CIT(A) to this extent and restore the matter to the file of the AO with a direction to verify, inter alia, (i) the factum of actual repayment of the loans, (ii) the status and functioning of the lender companies, and (iii) the independent creditworthiness and genuineness of the sources of funds of the lenders, and to decide the issue afresh in accordance with law, after affording reasonable opportunity of ITA No.607/Ahd/2024 DCIT vs. Sukham Properties Pvt.Ltd. Asst. Year : 2020-21 14 being heard to the assessee. Thus, ground No. 2 raised by the Revenue is, therefore, allowed for statistical purposes. 12. In the result, the appeal of the Revenue is partly allowed for statistical purposes. Order pronounced in the Open Court on 26th March, 2025 at Ahmedabad. Sd/- Sd/- (SUCHITRA KAMBLE) JUDICIAL MEMBER (MAKARAND V. MAHADEOKAR) ACCOUNTANT MEMBER अहमदाबाद/Ahmedabad, िदनांक/Dated 26/03/2025 टी.सी.नायर, व.िन.स./T.C. NAIR, Sr. PS आदेश की #ितिलिप अ$ेिषत/Copy of the Order forwarded to : 1. अपीलाथ% / The Appellant 2. #&थ% / The Respondent. 3. संबंिधत आयकर आयु' / Concerned CIT 4. आयकर आयु' ) अपील ( / The CIT(A)-(NFAC), Delhi 5. िवभागीय #ितिनिध , आयकर अपीलीय अिधकरण , राजोकट/DR,ITAT, Ahmedabad, 6. गाड\u0010 फाईल / Guard file. आदेशानुसार/ BY ORDER, स&ािपत #ित //True Copy// सहायक पंजीकार (Asstt. Registrar) आयकर अपीलीय अिधकरण, ITAT, Ahmedabad 1. Date of dictation (word processed by Hon’ble AM in his laptop) : 25.3.2025 2. Date on which the typed draft is placed before the Dictating Member. : 25.3.2025 3. Date on which the approved draft comes to the Sr.P.S./P.S : 4. Date on which the fair order is placed before the Dictating Member for pronouncement. : 5. Date on which fair order placed before Other Member : 6. Date on which the fair order comes back to the Sr.P.S./P.S. : 26.3.25 7. Date on which the file goes to the Bench Clerk. : 26.3.25 8. Date on which the file goes to the Head Clerk. : 9. The date on which the file goes to the Assistant Registrar for signature on the order. : 10. Date of Despatch of the Order : "