ACIT, New Delhi V. Sh. Subhash Chand Aggarwal, Saharanpur

ITA 1178/DEL/2015

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 4499 (ITAT-DELHI)
• Duration Of Justice: 3 year(s) 11 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-02-2019
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: G
• Assessment Year: 2012-2013
• Appeal Filed On: 27-02-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: S S RANA
• Keywords: Unexplained investment; Search and seizure; Valuation report
• Section: 271(1)(c); 143(3); 131

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: G: NEW DELHI) BEFORE SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER ITA NO:- 1178/DEL/2015 (ASSESSMENT YEAR: 2012-13) ACIT CENTRAL CIRCLE- 4 NEW DELHI VS. SUBHASH CHAND AGGARWAL R/O. 2/1425, WHITE HOUSE DELHI ROAD SAHARANPUR PAN NO: AAMPA4754D APPELLANT RESPONDENT REVENUE BY : SH. S.S. RANA, CIT(DR) ASSESSEE BY : SH. SHAILESH GUPTA, ADV. ORDER PER: ANADEE NATH MISSHRA, AM THIS APPEAL BY REVENUE IS FILED AGAINST THE ORDER DAT ED 18.12.2014 OF LD. COMMISSIONER OF INCOME TAX (APPEALS) [CIT(A) FOR SHORT] FOR ASSESSMENT YEAR (AY' FOR SHORT) 2012-13. SEARCH AND SEIZU RE OPERATIONS UNDER SECTION (U/S FOR SHORT) 132 OF INCOME TAX ACT, 1961 (IT ACT FOR SHORT) WERE CARRIED OUT IN THE PREMISES OF VARIOUS CASES OF SMC GROUP OF CASES ON 04.08.2011, INCLUDING IN THE PREMISES OF THE ASSESSE E. CASH AMOUNTING TO RS. 19,50,000/- WAS FOUND FROM THE PREM ISES OF THE ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 2 OF 10 AMOUNTING TO RS. 19,50,000/- WAS FOUND FROM THE PREM ISES OF THE ASSESSEE. FURTHER, JEWELLERY VALUED AT RS. 1,09,72,957/- WAS ALSO FOUND FROM THE PREMISES OF THE ASSESSEE. IN ASSESSMENT ORDER DATED 31.03.2014 U/S 143(3) OF THE IT ACT, THE AO MADE AN ADDITION OF RS. 9,75,000/- ON ACCOUNT OF CASH FOUND FROM THE ASSESSEES PREMISES AT THE TIME OF SEARCH AND SEIZURE OPERATIONS. THE AO ALSO MADE AN ADDITION O F RS. 1,09,72,957/- ON ACCOUNT OF JEWELLERY FOUND FROM THE ASSESSEES PREMISES. THE RELEVANT PORTION OF THE ASSESSMENT ORDER IS REPRODUCED AS UNDER: 4. DURING THE SEARCH OPERATION, CASH AMOUNTING TO RS.19,50,000/- WAS FOUND FROM 2/1425, WHITE HOUSE, D ELHI ROAD, SAHARANPUR, U.P. WHICH IS RESIDENCE OF SH. SU BHASH CHAND AGGARWAL AND SH. SANJAY AGGARWAL. IT WAS STAT ED BY SH. SUBHASH CHAND AGGARWAL THAT THIS CASH BELONG TO HIM AND HIS SON SH. SANJAY AGGARWAL AND SMT. SHUBHRA AGGARWAL, W/O SH. SANJAY AGGARWAL. IT MEANS HALF CASH OF RS.9,75,000/ - BELONG TO SH. SUBHASH CHAND AGGARWAL. 4.1.1 VIDE ORDER SHEET ENTRY DATED 14.02.2014 THE A SSESSEE WAS ASKED CATEGORICALLY TO EXPLAIN HOW THIS AMOUNT IS DECLARED IN HIS RETURN OF INCOME. IN RESPONSE TO THIS QUERY THE ASSESSEE MADE FOLLOWING SUBMISSIONS VIDE REPLY DATED 20.02.2 014 : 'THE CASH FOUND DURING THE COURSE OF SEARCH WE WOUL D LIKE TO DRAW YOUR KIND ATTENTION TO THE WORKING SHEET IN RE SPECT OF ASSESSEE WISE CASH FOUND DURING THE COURSE OF SEARC H AND WORKING SHEET IN RESPECT OF CASH IN HAND AS PER THE BOOKS OF ACCOUNT OF THOSE ASSESSEE WHOSE NAME IS APPEARING O N THE WORKING SHEET OF DEPARTMENT ON THE DATE OF SEARCH, AS PER 'WHICH THE CASH IN HAND AS PER BOOKS OF ACCOUNT WAS RS.2,57.87.960/- AND CASH FOUND DURING THE COURSE O F SEARCH IS RS.66,32,319/-. AS SUCH CASH FOUND DURING THE COURS E OF SEARCH IS LESS THAN THE CASH IN HAND AS PER BOOKS OF ACCOU NT AS SUCH THE SAME NEEDS NO INTERVENTION'. ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 3 OF 10 4.1.2 I HAVE GONE THROUGH THE ABOVE SUBMISSIONS AND FOUND NO FORCE IN IT AS AN AMOUNT OF RS.9,75,000/- IS TREATE D AS UNEXPLAINED AMOUNT ON THE DATE OF SEARCH. THE ASSES SEE FAILED TO DISCLOSE THIS UNEXPLAINED AMOUNT. HENCE, AN ADDI TION OF RS.9,75,000/- MADE ON A/C OF UNEXPLAINED CASH FOUND /SEIZED DURING THE SEARCH AND TAXED ACCORDINGLY. (ADDITION: RS.9,75,000/-) 4.2 IN THE FACTS & CIRCUMSTANCES OF CASE AS DISCUSS ED ABOVE I AM SATISFIED THAT THE ASSESSEE HAS CONCEALED & FURN ISHED THE INACCURATE PARTICULARS OF INCOME TO THE TUNE OF RS. 9,75,000/- WITHIN MEANING OF SECTION 271(L)(C). THEREFORE, ASS ESSEE IS LIABLE FOR THE LEVY OF PENALTY U/S 271(L)(C). THE PROCEEDI NGS U/S 271(L)(C) ARE INITIATED SEPARATELY. 5. JEWELLERY OF RS.1,09,72,957/- FOUND AND OUT OF W HICH RS.43,72,167/- WAS SEIZED DURING THE COURSE OF SEAR CH (LAST DATE OF OPERATION OF LOCKER 6.6.2011). VIDE ORDER S HEET ENTRY DATED 14.02.2014 THE ASSESSEE WAS ASKED CATEGORICAL LY TO EXPLAIN SOURCE OF INVESTMENT OF JEWELLERY. IN RESPO NSE TO THIS QUERY THE ASSESSEE MADE FOLLOWING SUBMISSIONS VIDE REPLY DATED 20.02.2014: 'WITH REFERENCE TO QUERY TO EXPLAIN THE JEWELLERY F OUND DURING THE COURSE OF SEARCH WE WOULD LIKE TO DRAW YOUR KIN D ATTENTION TO THE WORKING SHEET IN RESPECT OF JEWELLERY FOUND DURING THE COURSE OF SEARCH AND WORKING SHEET IN RESPECT OF JE WELLERY AS PER WEALTH TAX RETURN OF IMMEDIATE PREVIOUS ASSESSM ENT YEAR BEFORE THE DATE OF SEARCH, AS PER WHICH THE JEWELLE RY AS PER WEALTH TAX RETURN WAS RS.4,94,89,342/- AND JEWELLER Y FOUND DURING THE COURSE OF SEARCH IS RS.2,84,64,840/-. AS SUCH JEWELLERY FOUND DURING THE COURSE OF SEARCH IS LESS THAN THE JEWELLERY SHOWN IN THE WEALTH TAX RETURN AS SUCH TH E SAME NEEDS NO INTERVENTION'. 5.1 I HAVE GONE THROUGH THE ABOVE SUBMISSIONS AND F OUND NO FORCE IN IT. THEREFORE, AN AMOUNT OF RS.1,09,72,957 /- IS TREATED AS UNEXPLAINED INVESTMENT IN THE JEWELLERY. HENCE, A N ADDITION OF RS. 1,09,72,957/- MADE ON A/C OF UNEXPLAINED INV ESTMENT IN JEWELLERY AND TAXED ACCORDINGLY. (ADDITION: RS.1,09,72,957/-) ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 4 OF 10 5.2 IN THE FACTS & CIRCUMSTANCES OF CASE AS DISCUSS ED ABOVE I AM SATISFIED THAT THE ASSESSEE HAS CONCEALED & FURN ISHED THE INACCURATE PARTICULARS OF UNDISCLOSED INCOME TO THE TUNE OF RS.1,09,92,957/- WITHIN MEANING OF SECTION 271(1)(C ). THEREFORE, ASSESSEE IS LIABLE FOR THE LEVY OF PENAL TY U/S 271(L)(C). THE PROCEEDINGS U/S 271(1)(C) ARE INITIA TED SEPARATELY. 2 . AGGRIEVED, THE ASSESSEE FILED APPEAL BEFORE THE LD. CIT(A) WHO, VIDE IMPUGNED ORDER DATED 18.12.2014 DELETED THE AFORESAI D ADDITIONS. THE RELEVANT PORTION OF THE IMPUGNED ORDER OF THE LD. C IT(A) IS REPRODUCED AS UNDER: 4. THE ONLY EFFECTIVE GROUND OF APPEAL IS THE SECO ND GROUND NUMBERED 1.2 WHEREIN THE APPELLANT HAS CHALLENGED T HE ADDITIONS OF RS.9,75,000/- BEING 50% OF CASH AMOUNT ING TO RS. 19,50,000/- FOUND IN THE COURSE OF SEARCH, AND RS. 1,09,72,957/- BEING JEWELRY FOUND DURING THE COURSE OF SEARCH OUT OF WHICH JEWELRY OF THE VALUE OF RS.43,72,167/- WAS SEIZED. WE SHALL DISCUSS THESE TWO ADDITIONS SEPARATELY. 5.1 DURING THE COURSE OF SEARCH CASH AMOUNTING TO R S. 19,50,000/- WAS FOUND FROM THE RESIDENCE OF THE APP ELLANT AT 2/1425, WHITE HOUSE, DELHI ROAD, SAHARANPUR (UP) OUT OF WHICH RS. 19,00,000/- WAS SEIZED. AT THE SAID RESIDENCE, THE APPELLANT RESIDES WITH HIS WIFE SMT. SUSHILA RANI, HIS SON SH . SANJAY AGGARWAL, AND HIS DAUGHTER-IN- LAW SMT. SUBHRA AGGA RWAL. AS PER THE BOOKS OF ACCOUNT REGULARLY MAINTAINED BY TH E APPELLANT, HIS SON AND DAUGHTER-IN-LAW, THE CASH BALANCE AS ON 01.08.2011 WAS RS.9,09,112/-, RS. 10,97,189/- AND RS. 10,54,99 3/-, RESPECTIVELY, TOTALING RS.30,61,295/-. THE AO HAS D ISBELIEVED THE CLAIM OF THE APPELLANT AND MADE THE ADDITION WI THOUT ASSIGNING ANY REASON OR CITING ANY EVIDENCE. THE BO OKS MAINTAINED BY THE APPELLANT HAVE ALSO NOT BEEN QUES TIONED OR REJECTED. THERE IS NO EVIDENCE TO CONCLUDE THAT THE CASH FOUND REPRESENTED UNDISCLOSED INCOME OF THE APPELLANT OR OTHER MEMBERS OF HIS FAMILY. THE ADDITION MADE CANNOT BE LEGALLY SUSTAINED AND IS DELETED. ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 5 OF 10 5.2 THE SECOND ADDITION MADE BY THE AO WAS ENTIRE J EWELRY OF THE VALUE OF RS. 1,09,72,957/- FOUND IN THE RESIDEN CE OF THE APPELLANT, INCLUDING ON THE PERSON OF THE FAMILY ME MBERS, OUT OF WHICH 2 ITEMS OF THE VALUE OF RS.43,72,167/- WERE S EIZED. AS PER THE WEALTH TAX RECORDS OF THESE MEMBERS, THE VA LUE OF JEWELRY DISCLOSED AMOUNTED TO RS. 1,46,48.448/- AS ON 31.03.2011. FROM THE DOCUMENTS FILED, I FIND THAT E VEN THE TWO SEIZED ITEMS DESCRIBED AS DIAMOND NECKLACE WEIGHI NG 116.900 GMS AND 71 GINNIES' WEIGHING 565.900 GMS ARE ALSO DULY DISCLOSED IN THE WEALTH TAX RECORDS OF SH. SANJAY A GGRAWAL & SONS (HUF) AS PER THE VALUATION REPORT DATED 23.03.2 011. THEREFORE, THERE IS NO BASIS TO REACH THE CONCLUSIO N THAT JEWELRY FOUND IN THE RESIDENCE OF THE APPELLANT WAS UNDISCL OSED. THE ADDITION MADE IS ERRONEOUS AND IS DELETED. 3. NOW, REVENUE HAS FILED THE APPEAL IN INCOME TAX APPEL LATE TRIBUNAL (ITAT FOR SHORT) IN WHICH THE FOLLOWING GROUNDS OF A PPEAL HAVE BEEN RAISED: ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE LD. CIT(A) HAS ERRED IN:- 1. THE ORDER OF THE CIT(A) IS NOT CORRECT IN LAW AN D FACTS. 2. ON THE FACTS AND CIRCUMSTANCES OF THE CASE THE L D. CIT(A) HAS ERRED IN LAW IN DELETING THE ADDITION OF CASH F OUND & SEIZED DURING THE COURSE OF SEARCH & SEIZURE OPERAT ION AMOUNTING TO RS.9,75,000/- MADE BY AO ON ACCOUNT OF UNEXPLAINED CASH. 3. ON THE FACTS AND CIRCUMSTANCES OF THE CASE THE-L D. CIT(A) HAS ERRED IN LAW IN DELETING THE ADDITION OF RS.1,0 9,72,957/- MADE BY AO ON ACCOUNT OF UNEXPLAINED INVESTMENT IN JEWELLERY. 4. THE APPELLANT CRAVES LEAVE TO ADD, AMEND ANY/ALL THE GROUNDS OF APPEAL BEFORE OR DURING THE COURSE OF HE ARING OF THE APPEAL. 4. AT THE TIME OF HEARING BEFORE US THE LD. CIT(DR) SUPP ORTED THE ADDITIONS MADE BY THE AO, AND FOR THIS PURPOSE HE RELI ED ON THE ORDER OF THE ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 6 OF 10 ASSESSMENT ORDER DATED 31.03.2014. THE LD. CIT(DR) ALSO RELIED ON THE FOLLOWING JUDICIAL PRECEDENTS: 1. R MALLIKA VS CIT [2017] 79 TAXMANN.COM 117 (SC) 2. CIT VS R MALLIKA [2013] 36 TAXMANN.COM 231 (MADRAS)/[2013] 219 TAXMANN 244 (MADRAS) 3. ASHOKBHAI H JARIWALA VS ACIT [2017] 84 TAXMANN.C OM 196 (SC)/[2017] 250 TAXMANN 14 (SC), 2017-TIOL-236-SC-I T 4. SUKH RAM VS ACIT 159 TAXMANN 385 (DELHI)/[2006] 285 ITR 256 (DELHI)/[2008] 204 CTR 336 5. KARUN DUTT SINGH VS CIT [2017] 85 TAXMANN.COM 17 7 (KERALA) 5. THE LD. COUNSEL FOR ASSESSEE SUPPORTED THE ORDER OF THE L D. CIT(A) FOR WHICH PURPOSE HE RELIED ON ORDER DATED 31.01.2019 OF COORDINATE BENCH OF ITAT, DELHI IN THE CASE OF ACIT VS MR. MOOLCHAND AGGRAWAL IN ITA NO. 1175/DEL/2015 FOR AY 2012-13 IN WHICH UNDER SIMILAR FACTS AND CIRCUMSTANCES, THE ISSUES REGARDING CASH AND JEWELLERY FOUND FROM THE ASSESSEES PREMISES WERE DECIDED IN FAVOUR OF THE ASSESSEE. 6. WE HAVE HEARD BOTH SIDES PATIENTLY. WE HAVE PERUSED AL L MATERIALS ON OUR RECORDS CAREFULLY. WE HAVE CONSIDERED THE JUDICIAL PR ECEDENTS BROUGHT TO OUR ATTENTION. WE HAVE ALSO CONSIDERED THE JUDICIAL PR ECEDENTS REFERRED TO IN THE RECORDS. WE ARE OF THE VIEW THAT THE RELIANCE PLACE D BY THE LD. CIT(DR) ON THE VARIOUS JUDICIAL PRECEDENTS DOES NOT ADVANCE THE CASE OF THE REVENUE BECAUSE THESE JUDICIAL PRECEDENTS ARE ON MATERIALLY DIFFE RENT AND CLEARLY DISTINGUISHABLE FACTS. IN THE CASE OF R MALLIKA VS CIT (SUPRA) AND CIT VS R MALLIKA (SUPRA), THE ASSESSEE HAD NOT DISCHARGED BURDEN AS REGARDS SO URCE ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 7 OF 10 FROM WHICH INVESTMENT HAD BEEN MADE. HOWEVER, IN THE CASE BEFORE US THE ASSESSEE HAD FURNISHED EXPLANATION TO THE AO AND HAD DISC HARGED THE BURDEN AS REGARDS THE SOURCE OF CASH / JEWELLERY FOUND FR OM THE ASSESSEES PREMISES. IN THE CASE OF ASHOKBHAI H JARIWALA VS ACIT (SUPRA), THERE WAS NOTHING ON RECORD TO SHOW THAT SISTER OF ASSESSEE WAS IN EXCL USIVE POSSESSION OF BEDROOM IN ASSESSEES HOUSE FROM WHERE CASH WAS SEI ZED AND FURTHER, THERE WAS CONTRADICTION IN STATEMENT OF ASSESSEE AND HIS SISTER WITH RESPECT TO OWNERSHIP OF ACTUAL AMOUNT IN CASH. THERE ARE NO SUCH FACTS IN THE CASE BEFORE US. IN THE CASE OF SUKH RAM VS ACIT (SUPRA), HUGE SUM OF CASH WAS FOUND FOR WHICH ASSESSEE EXPLAINED THAT SAID CASH BEL ONGED TO CERTAIN ORGANIZATION BUT DID NOT BRING ANY MATERIAL ON RECORD TO SUBSTANTIATE HIS EXPLANATION AND, MOREOVER, VERIFICATION OF BOOKS O F ACCOUNT OF SAID ORGANIZATION SHOWED NO CONNECTION WITH CASH RECOVERED FRO M ASSESSEE. HOWEVER, IN THE CASE BEFORE US THE CASH AND JEWELLERY FOU ND FROM THE ASSESSEES PREMISES ARE FULLY EXPLAINED BY THE CASH BALANCES AS PER BOOKS OF ACCOUNTS OF DIFFERENT PERSONS AND JEWELLERY DISCLOSED IN TH E WEALTH TAX RECORDS OF DIFFERENT PERSONS. IN THE CASE OF KARUN DUTT SINGH VS CIT (SUPRA), ADDITION ON ACCOUNT OF GOLD ORNAMENTS RECOVERED FROM TH E ASSESSEE WAS UPHELD AFTER REJECTING THE ASSESSEES EXPLANATION THAT IT BELONGED TO HIS EMPLOYER COMPANY, IN VIEW OF FACT THAT DIRECTOR OF EMP LOYER COMPANY IN HIS STATEMENT RECORDED UNDER SEC. 131 DENIED TO HAVE GIVEN ORNAMENTS TO ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 8 OF 10 ASSESSEE FOR SALE OR AS SAMPLES. THERE ARE NO SUCH FACTS IN TH E CASE BEFORE US. 6.1 WE FIND THAT THE CASH FOUND AT THE TIME OF SEARCH AND SE IZURE OPERATION U/S 132 OF IT ACT FROM THE PREMISES OF THE ASSE SSEE WAS LESS THAN THE CASH IN HAND AMOUNTING TO RS. 2,57,87,960/- AS PER BOOKS OF ACCOUNT. WE FURTHER FIND THAT THE JEWELLERY FOUND FROM THE A SSESSEES PREMISES WAS LESS THAN JEWELLERY VALUED AT RS 4,94,89,342/- AS PER W EALTH TAX RECORDS OF VARIOUS PERSONS. IN VIEW OF THE FOREGOING FACTS, IMPUG NED ORDER OF THE LD. CIT(A) WHEREIN HE DELETED THE AFORESAID ADDITIONS OF RS. 9,75,000/- AND RS. 1,09,72,957/-, NEEDS NO INTERFERENCE. THE CASH FOUND, A MOUNTING TO RS. 9,75,000/-, BEING LESS THAN CASH BALANCE AS PER BOOKS OF A CCOUNT; IS FULLY EXPLAINED BY CASH BALANCE AS PER BOOKS OF ACCOUNT. THE AO ERRED IN MAKING ADDITION OF THE AFORESAID AMOUNT OF RS. 9,75,000/-, W ITHOUT ANY REASONING AND IN THE ABSENCE OF ANY EVIDENCE TO SHOW THAT THE CASH FOUND WAS UNACCOUNTED OR UNEXPLAINED OR UNDISCLOSED. SIMILARLY, T HE JEWELLERY FOUND FROM THE PREMISES OF THE ASSESSEE IS ALSO FULLY EXPLAINED BY WEALTH TAX RECORDS OF VARIOUS PERSONS. THE AO ERRED IN MAKING THE A DDITION OF THE AFORESAID AMOUNT OF RS. 1,09,72,957/- WITHOUT PROPER REASONING, AND IN THE ABSENCE OF ANY EVIDENCE TO SHOW THAT THE JEWELLERY FOUN D WAS UNACCOUNTED OR UNEXPLAINED OR UNDISCLOSED. IN THE FACTS AND CIRCUMSTA NCES OF THE CASE, THE AO HAD NO BASIS TO MAKE THE ADDITIONS, WHEN THE CASH FOUND WAS EXPLAINED BY CASH BALANCE AS PER BOOKS OF ACCOUNT AND WHEN THE JEWELLERY ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 9 OF 10 FOUND WAS FULLY EXPLAINED BY JEWELLERY DISCLOSED IN WE ALTH TAX RECORDS OF VARIOUS PERSONS. IN VIEW OF THE FOREGOING, THERE IS NO MATERIAL TO WARRANT ANY INTERFERENCE BY US WITH THE IMPUGNED ORDER OF THE LD. CIT(A). WE FIND THAT IN VIEW OF THE FACTS AND CIRCUMSTANCES OF THIS CASE, THE ORDER OF THE LD. CIT(A) IS SOUND IN LAW. THEREFORE, WE DECLINE TO INTER FERE WITH THE IMPUGNED ORDER OF THE LD. CIT(A) AND UPHOLD THE ORDER OF THE LD. CIT(A). IN THE RESULT, APPEAL OF THE REVENUE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 14 TH DAY OF FEBRUARY, 2019. SD/- SD/- (SUDHANSHU SRIVASTAVA) (ANADEE NATH MISSH RA) JUDICIAL MEMBER ACCOUNTANT MEMBE R DATED: 14.02.2019 BIDHAN COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI ITA NO:- 1178/DEL/2015 SUBHASH CHAND AGGARWAL PAGE 10 OF 10 DATE OF DICTATION 13.02.2019 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 13.02.2019 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE OTHER MEMBER 13.02.2019 DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR. PS/PS 13.02.2019 DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE DICTATING MEMBER FOR PRONOUNCEMENT 13.02.2019 DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR. PS/PS 13.02.2019 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT DATE ON WHICH THE FILE GOES TO THE BENCH CLERK DATE ON WHICH THE FILE GOES TO THE HEAD CLERK THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT REGISTRAR FOR SIGNATURE ON THE ORDER DATE OF DISPATCH OF THE ORDER