ACIT, Karnal V. M/s. Karnal Communication Network (P) Ltd., Karnal

ITA 1190/DEL/2012

• Counselvise Citation: [2014] 140 COUNSELVISE.COM (IT) 82174 (ITAT-DELHI)
• Duration Of Justice: 2 year(s) 8 month(s) 26 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-12-2014
• Appeal Filed By: Department
• Order Result: Allowed
• Bench Allotted: D
• Next Hearing Date: 15-10-2014
• Assessment Year: 2003-2004
• Appeal Filed On: 09-03-2012
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Assessee Lawyers: SB GUPTA
• Keywords: Reopening of assessment; Depreciation; Income from undisclosed sources; Additional evidence; Bad and doubtful debts
• Section: 148

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH D, NEW DELHI) BEFORESHRI T.S. KAPOOR, ACCOUNTANT MEMBER AND SHRI A. T. VARKEY, JUDICIAL MEMBER I.T.A. NO.1190 /DEL/2012 ASSESSMENT YEAR : 2003-04 ACIT, CIRCLE, VS. M/S. KARNAL COMMUNICAITON KARNAL NETWORK (P) LTD., C/O YOVESH TOWER, KARNAL GIR / PAN:AAACCK2110L (APPELLANT) (RESPONDENT) APPELLANT BY : SHRI VIVEK NANGIA, SR. DR RESPONDENT BY : SHRI S B GUPTA, CA ORDER PER T.S. KAPOOR, AM: THIS IS AN APPEAL FILED BY REVENUE AGAINST THE ORD ER OF LD. CIT(A) DATED 01.12.2011. THE REVENUE HAS TAKEN FOLLOWING GROUNDS OF APPEAL: 1) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CA SE, THE LD. CIT(A) HAS ERRED IN LAW IN DELETING THE ADDITION OF RS.11,43,400/- ON ACCOUNT OF OPERATIONAL EXPENSES. 2) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E, THE LD. CIT(A) HAS ERRED IN LAW IN DELETING THE ADDITION OF RS.40,979/- ON ACCOUNT OF BAD DEBTS. 3) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E THE LD. CIT(A) HAS ERRED IN LAW IN DELETING THE ADDITION OF RS.64, 65,000/- ON ACCOUNT OF INCOME FROM UNDISCLOSED SOURCES. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESSE E HAD FILED RETURN OF INCOME ON 20.08.2004 IN RESPONSE TO NOTICE U/S 148 DECLARING LOSS OF RS.6,17,600/-. DURING ASSESSMENT PROCEEDINGS, THE A.O. REQUIRED THE LD. A.R. TO PRODUCE SHRI YOGESH KUMAR, DIRECTOR OF THE COMPANY FOR 2 ITA NO.1190/DEL/2012 EXAMINATION AND FOR ASCERTAINING THE SOURCES OF INV ESTMENT IN SHARES ETC. HOWEVER THE DIRECTOR OF THE COMPANY WAS NOT PRODUCE D NOR ANY BOOKS WERE PRODUCED. THEREFORE, A.O. COMPLETED THE ASSESSMENT AFTER MAKING VARIOUS ADDITIONS. THE OPERATIVE PART OF ORDER OF A.O. REA DS AS UNDER: 3. OPERATIONAL EXPENSES:- OPERATIONAL EXPENSES HAS BEEN SHOWN AT RS.L2,03,400 /- AS AGAINST RS.60,000/- SHOWN IN THE PREVIOUS YEAR. THE DIFFERE NCE OF RS.L1,43,400/- IS ADDED BACK TO THE INCOME OF THE A SSESSEE. 6. BAD DEBTS:- BAD DEBTS OF RS.40,979/- HAS BEEN CLAIMED IN THIS Y EAR. THE ASSESSEE HAS NOT PRODUCED ANY DOCUMENTARY EVIDENCE AND NO EF FORTS HAVE BEEN MADE TO RECOVER THE SAME, HENCE, THESE ARE NOT ALLO WED FOR WANT OF EVIDENCE AND ADDED BACK TO THE INCOME OF THE ASSESS EE. 7. INCOME FROM UNDISCLOSED SOURCES: THE ASSESSEE HAS SHOWN SECURITIES PREMIUM AT RS.51, 72,000/- AND 6% NON CUMULATIVE REDEEMABLE PREFERENCE SHARES AMOUNTI NG TO RS.12,93,000/-. THE ASSESSEE HAS PRODUCED DOCUMENTS REGARDING 12,93,000/- BUT THE SOURCE OF INVESTMENT HAS NOT BE EN EXPLAINED. SIMILARLY THE ASSESSEE NEITHER PRODUCED ANY DIRECTO R OF THE COMPANY NOR ANY VERIFICATION OF GENUINENESS OF THE SHARES. IN THE ABSENCE OF ANY DOCUMENTARY EVIDENCE THIS CANNOT BE SAID TO BE GENUINE AND ARE DISALLOWED. MOREOVER, THE ASSESSEE COMPANY ALREADY NOT EXPLAINED, WHO WILL PURCHASE THE SHARES FROM SUCH A COMPANY WH ICH IS ALREADY UNDER LIQUIDATION. THEREFORE AN ADDITION OF RS.64.6 5.000/- IS MADE TO THE INCOME OF THE ASSESSEE AS INCOME OF THE ASSESSE E FROM UNDISCLOSED SOURCES. SUBJECT TO THE ABOVE OBSERVATIONS, TOTAL INCOME OF THE ASSESSEE IS COMPUTED AS UNDER:- LOSS AS DECLARED BY THE ASSESSEE (-) 6,24,712 /- ADDITION AS PER PARA 3 ABOVE. 11,43,400/- 3 ITA NO.1190/DEL/2012 ADDITION AS PER PARA 4 ABOVE. 99,509/- ADDITION AS PER PARA 5 ABOVE 99, 999/- ADDITION AS PER PARA 6 ABOVE 40,979/- ADDITION AS PER PARA 7 ABOVE 64,65,000/- TOTAL INCOME 72,24,175/- NO DEPRECIATION IS ALLOWED AS THE ASSETS DO NOT BEL ONGING TO THE ASSESSEE BUT BELONGS TO THE PARENT COMPANY ON WHICH DEPRECIATION MIGHT HAVE BEEN CLAIMED BY COMPANY. ASSESSED: ISSUE REQUISITE DOCUMENTS TO THE ASSESSEE . CHARGE INTEREST U/S 234BAND 234A. PENALTY NOTICE U/S 271(1)(C) HAS SEPARATELY BEEN IS SUED. 3. AGGRIEVED, THE ASSESSEE FIELD APPEAL BEFORE LD. CIT(A). LD. CIT(A) DELETED THE ABOVE ADDITIONS BY HOLDING AS UNDER: I) OPERATIONAL EXPENSES: 4.03 THE ISSUE IS EXAMINED. THE FACTS ARE THAT THE APPELLANT CLAIMED EXPENSES OF RS.12,03,400/- UNDER THE HEAD 'OPERATIO NAL EXPENSES', WHICH COMPRISES OF AS FOLLOWS:- CURRENT YEAR LOST YEAR FUEL EXPENSES 60,000/- 60,000/- ESPN & STAR SPORTS CHARGES 4,05,110/- 00 STAR PACKAGE CHARGES 7,38,290/- 00 12,03,400/- 60,000/- THERE WAS AS SUCH INCREASE OF RS.11,43,400/- IN THE 'OPERATIONAL EXPENSES' OVER THE LAST YEAR. THE SAME WAS STATED T O BE ON ACCOUNT OF TAKING OF 2 NEW PACKAGES FOR TRANSMISSION FROM ESPN AND FROM STAR FOR WHICH ADDITIONAL PAYMENTS WERE MADE OF RS.11,43 ,400/- DURING THE YEAR UNDER CONSIDERATION. THE APPELLANT SUBMITT ED THAT EXPENSES OF RS. 4,05,110/- WAS TO BE INCURRED IN PAY CHANNEL OF ESPN & IN STAR SPORTS AND RS.7,38,290/- ON STAR PACKAGE. THE A.O. DISALLOWED THE ENTIRE INCREASE IN THE 'OPERATIONAL EXPENSES' WITHO UT GIVING ANY 4 ITA NO.1190/DEL/2012 REASON THEREOF. IN VIEW OF THESE FACTS, THE DISALLO WANCE MADE BY THE A.O. CANNOT BE SUSTAINED AND HENCE IS HEREBY DIRECT ED TO BE DELETED. II) BAD DEBTS: 4.07 THE RELEVANT PARA F FROM THE WRITTEN SUBMISSIO NS FILED BY THE APPELLANT IS REPRODUCED BELOW:- 'THE APPELLANT COMPANY HAD DEBITED RS.40979/ - TO T HE PROFIT AND LOSS ACCOUNT OF THE ASSESSMENT YEAR IN QUESTION ON ACCOU NT OF BAD DEBTS AMOUNT WHICH ARE NOT RECOVERABLE FROM THE CABLE OPE RATORS DUE TO DIFFERENCE IN RATES AND EXCESSIVE CHARGES AS ALLEGE D BY CABLE OPERATORS. THE APPELLANT COMPANY HAD FILED THE NECESSARY DETAI LS OF BAD DEBITED TO THE PROFIT AND LOSS ACCOUNT TO THE LEARNED ASSES SING OFFICER DURING THE COURSE OF ASSESSMENT. SECTION 36(1) (VII) OF THE 1. T.ACT 1961 PROVIDES T HAT AMOUNT OF ANY BAD DEBTS WHICH IS WRITTEN OFF AS IRRECOVERABLE IN THE ACCOUNT OF THE ASSESSEE FOR THE PREVIOUS YEAR, IT ALLOWABLE AS DED UCTION SUBJECT TO FOLLOWING CONDITION LAID DOWN IN SECTION36(2): (A) THE DEBT HAS BEEN TAKEN INTO ACCOUNT IN COMPUTI NG THE INCOME OF THE ASSESSEE OF THE PREVIOUS YEAR, IN WHICH THE AMO UNT IS WRITTEN OFF OR AN EARLIER PREVIOUS YEAR OR (B) IT REPRESENTS MONEY LENT IN THE ORDINARY COURSE OF BUSINESS OF MONEY LENDING WHICH IS CARRIED ON THE ASSESSEE. MOREOVER IT WAS HELD IN THE CASE OF AJEET KUMAR C. KAMDAAR VS. CIT (2005) 1 SOT183 (MUMBAI) THAT IT IS NOT FOR THE ASS ESSEE TO ESTABLISH THAT THE DEBT HAD BECOME IN THE PREVIOUS YEAR. IN O THER WORDS IT IS NOT OBLIGATORY FOR THE ASSESSEE TO PLACE DEMONSTRATIVE PROOF FOR ESTABLISHING A DEBT AS BAD. FURTHER, IT WAS HELD IN THE CASE OF NEW DEAL FINANC E & INVESTMENT LTD. VS. DEPUTY CIT [2000J 74 ITD 469/ 69TT J (CHEN NAI) 410 THAT IF DEBT HAS BEEN WRITTEN OFF AS IRRECOVERABLE IN THE A CCOUNTS OF THE ASSESSEE FOR THE PREVIOUS YEAR, IT WILL SUFFICE FOR CLAIMING IT AS BAD 5 ITA NO.1190/DEL/2012 DEBT. IT IS FOR THE ASSESSEE TO DECIDE WHETHER THE DEBT HAS BECOME BAD OR NOT AND THE A.O. CAN NEVER INSIST ON PRODUCTION OF DEMONSTRATIVE AND INFALLIBLE PROPOSE BECAME BAD. THUS ALL THE CONDITIONS FOR THE ALLOW ABILITY OF BA D DEBT HAVE BEEN COMPLIED WITH IN THE CASE OF THE APPELLANT COMPANY AS PRESCRIBED IN SECTION36 OF THE INCOME TAX. ACT 1961 AND THE ADDIT ION MADE BY THE LD. A.O. ON THIS ACCOUNT IS PURELY ON SURMISE AND B AD IN LAW AND NEED TO BE DELETED. ' III) ISSUE OF SHARES: 5.03 THE ISSUE IS EXAMINED. THE FACTS ARE THAT THE A.O. NOTED THAT THE APPELLANT COMPANY ALLOTTED 6% REDEEMABLE PREFERENCE SHARES OF S.12,93,000/- TO ITS PARENT COMPANY ON A PREMIUM OF RS.51,72,000/-. THE A.O. HELD THE SAME AS UNEXPLAINED FOR WANT OF S OURCE OF THIS INVESTMENT AND NON- PRODUCTION OF THE DIRECTOR AND ADDED THE SAME TO THE INCOME OF THE APPELLANT WHICH IS CHALLENGED BY THE APPELLANT VIDE GROUND NO 7 OF APPEAL. THE SUBMISSION MADE BY THE A PPELLANT HAS BEEN REPRODUCED ABOVE. 5.04 IN VIEW OF THE FACTS DISCUSSED ABOVE, IT IS NO TED THAT NO MONEY WAS INTRODUCED AS FRESH CAPITAL ON ACCOUNT OF PREFE RENCE SHARES ISSUED BY THE APPELLANT. THE APPELLANT HAD TO PAY A SUM OF RS.83,57,017/- TO CITY CABLE LTD. AT THE BEGINNING OF THE YEAR. THE TOTAL AMOUNT PAYABLE AFTER CREDITING THE CHARGES PA YABLE OF THE YEAR TO THE CITY CABLE LTD BECAME RS.1,58,07,429/-. THE APPELLANT ISSUED PREFERENCE SHARE BY WAY OF BOOK ENTRY AGAINST THE C REDIT BALANCE OF CITY CABLE LTD TO THE EXTENT OF RS.64,65,000/- AND THE SAME WAS DEBITED TO THE ACCOUNT OF CITY CABLE NETWORK. IN VI EW OF THESE FACTS, THE SOURCE OF ISSUE OF SHARES IS EXPLAINED BEING IT WAS MERELY TRANSFER FROM THE ACCOUNT OF CITY CABLE PVT. LTD. TO THE CAP ITAL ACCOUNT AND HENCE, NO ADDITION IS CALLED FOR ON THIS ACCOUNT. T HE ADDITION MADE BY THE A.O. IS, THEREFORE, DELETED. 4. AGGRIEVED, THE REVENUE IS IN APPEAL BEFORE US. 6 ITA NO.1190/DEL/2012 5. AT THE OUTSET, LD. D.R. SUBMITTED THAT BOOKS OF ACCOUNTS WERE NOT PRODUCED AND EXPENSE OF ASSESSEE HAD INCREASED MANI FOLD. IT WAS SUBMITTED THAT EARLIER, LD. CIT(A) HAD QUASHED THE ASSESSMENT FOR VIOLATION OF PROVISIONS OF SECTION 148 AND HONBLE ITAT HAD SET ASIDE THE ORDER OF LD. CIT(A) AND HAD DIRECTED CIT(A) TO DECIDE THE ISSUE ON MERITS. IT WAS SUBMITTED THAT LD. CIT(A) WITHOUT CALLING FOR REMAN D REPORT FROM A.O., HAS DECIDED THE ISSUE IN FAVOUR OF THE ASSESSEE. IT WAS SUBMITTED THAT FROM THE ORDER OF LD. CIT(A) IT IS NOT APPARENT THAT ANY VER IFICATION WAS DONE OR NOT. 6. LD. A.R. ON THE OTHER HAND INVITED OUR ATTENTION TO PAPER BOOK PAGES 5 & 6 AND SUBMITTED THAT IT IS NOT CORRECT THAT REMAN D REPORT WAS NOT OBTAINED AND IT WAS SUBMITTED THAT THE A.O. HAD NOT COMMENTE D UPON MERITS AND HAD LEFT IT OPEN TO LD. CIT(A) TO DECIDE THE ISSUE ON M ERITS. IN HIS REJOINDER, LD. D.R. SUBMITTED THAT LD. CIT(A) HAS NOT MADE ANY FIN DINGS AND IN FACT HE HAS REPRODUCED THE WRITTEN SUBMISSIONS OF ASSESSEE. 7. WE HAVE HEARD RIVAL PARTIES AND HAVE GONE THROUG H THE MATERIAL PLACED ON RECORD. WE FIND THAT IN I.T.A. NO. 142 AND143 F OR ASSESSMENT YEARS 2002-03 AND 2003-04 THE ITAT HAS REMITTED BACK THE APPEALS FILED BY REVENUE TO THE OFFICE OF LD. CIT(A). THE HONBLE ITAT HAD UPHELD THE REOPENING OF THE ASSESSMENT AND ON MERITS, THE SAME WAS RESTORED TO LD. CIT(A) WITH A DIRECTION TO LD. CIT(A) TO ADMIT ADDI TIONAL EVIDENCE IN ACCORDANCE WITH LAW. THE RELEVANT FINDINGS ARE REP RODUCED BELOW: 6. WE HAVE HEARD THE LEARNED DR, PERUSED THE MATE RIAL AVAILABLE ON RECORD. AS THE FACTS EMERGE, ASSESSEE COMPANY HA D NOT FILED ANY VOLUNTARY RETURN OF INCOME. AO CAME INTO THE KNOWLE DGE OF HUGE EXPENSES WHICH EMANATED FROM THE CASE OF THE DIRECT OR. CIT(A) HAS HELD THAT AO'S REASONS ARE VAGUE AND DOES NOT INDIC ATE THE SOURCE OF THIS INFORMATION. IN OUR VIEW, CIT(A) HAS LOST SIGH T OF THE FACT THAT THE AO HAS HIMSELF MENTIONED THAT THE SOURCE OF INFORMA TION IS FROM THE 7 ITA NO.1190/DEL/2012 CASE OF MR. YOGESH KUMAR, DIRECTOR. IT HAS BEEN MENTIONED THAT NO RETURN OF INCOME HAS BEEN FILED AND VERIFICATION OF EXPENSES BECOMES IMPERATIVE. IN OUR VIEW, THE AO WAS RIGHT IN ASSUMI NG JURISDICTION U/S 148. CIT(A), IN OUR OPINION, WAS NOT CORRECT IN HOL DING THE A.O. TO BE IN FAULT MORE SO WHEN THE ALLEGATIONS MADE ARE NOT CORROBORATED AS THE ANSWER LIES IN THE REASONS ITSELF. APROPOS HOLD ING THAT AO'S INFERENCE THAT EXPENDITURE PRE-SUPPOSES INCOME IS A LSO NOT CORRECT BECAUSE THE AO WOULD LIKE TO VERIFY HUGE EXPENSES A RE PROPERLY DEBITED OR NOT AND THE SAME MAY BE INGREDIENT OF ES CAPEMENT OF INCOME. NOTICE U/S 148 DOES NOT PUT A BURDEN ON AO TO BE FOOLPROOF ABOUT ESCAPEMENT. WHAT IS REQUIRED IS A PRIMA FACIE SATISFACTION BASED ON SOME INFORMATION. THE SAME IS FOUND TO BE PRESENT IN THIS CASE. IN OUR VIEW, ASSUMPTION OF JURISDICTION BY AO CANNOT BE FOUND FAULT WITH WITHOUT SHOWING A SIMILARITY BETWEEN CIT (A)'S ORDER FOR ASSTT. YEARS 2001-02 AND 2002-03. IN VIEW THEREOF, WE UPHOLD THE REOPENING OF ASSESSMENT. 7. COMING TO THE MERITS OF THE CASE, WE FIND SUBSTA NCE IN THE PROPOSITION OF LEARNED DR. ASSESSEE DID NOT PRODUCE ANYTHING IN THE ASSESSMENT PROCEEDINGS, THE ENTIRE RECORD AND ACCOU NT BOOKS WERE PRODUCED BEFORE CITCA). THERE IS NO REFERENCE TO AN Y ADDITIONAL EVIDENCE, THE REASONS OFFERED BY ASSESSEE FOR NON P RODUCTION AND CIT(A) HAS GIVEN THE RELIEF WITHOUT ADMITTING ADDI TIONAL EVIDENCE BY RECORDING THE SUFFICIENCY' OF REASONS ON THE PART O F ASSESSEE. AT LEAST THERE IS NO MENTION IN THE ORDER OF CIT(A) IN THIS BEHALF. IN OUR VIEW, CITCA)'S ORDER CANNOT BE CALLED A REASONED AND BALA NCED ORDER. IN VIEW THEREOF, WE SET ASIDE THE MERITS BACK TO THE F ILE OF CIT(A) TO PROCEED WITH IT IN ACCORDANCE WITH LAW I.E. PROPER ADMISSION OF ADDITIONAL EVIDENCE, RECORDING REASONS WHY ASSESSEE WAS PREVENTED IN PRODUCING THE SAME BEFORE AO AND THEREAFTER, DECIDI NG THE MERITS. 8. IN VIEW THEREOF, REVENUE'S APPEAL IS PARTLY ALL OWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON SO' JUNE, 200 9. 8. WE FIND THAT LD . CIT(A) HAS ALLOWED RELIEF TO T HE ASSESSEE ON MERITS WITHOUT CONFRONTING THE EVIDENCES FILED BY IT TO A. O. BEFORE THE A.O., NO 8 ITA NO.1190/DEL/2012 BOOKS WERE PRODUCED AND, THEREFORE, A.O. HAD MADE A DDITION ON THE BASIS OF MATERIAL ON RECORD. IN THE FIRST ROUND, THE HON BLE TRIBUNAL VIDE ORDER DATED 30.06.2009 HAD DIRECTED LD. CIT(A) TO ACCEPT THE ADDITIONAL EVIDENCE AFTER RECORDING REASONS AS TO WHY ASSESSEE WAS PREV ENTED TO FILE THESE BEFORE A.O. THE REMAND REPORT REFERRED TO BY LD. A.R. IS DATED 07.09.2007 WHICH DEFINITELY RELATES TO FIRST ROUND AS PER LD. CIT(A) S EARLIER DIRECTION AS THE DATE OF REMAND REPORT IS 07.09.2007 WHEREAS THE ORD ER OF ITAT IS DATED 30.06.2009. THE CONTENTION OF LD. A.R. THAT REMAND REPORT WAS OBTAINED IS NOT CORRECT AS OTHER ORDER OF ITAT NO REMAND REPORT HAS BEEN OBTAINED. LD. CIT(A) HAS DECIDED THE ISSUE ON MERITS IN THE SECON D ROUND WITHOUT OBTAINING REMAND REPORT WHICH IS IN VIOLATION OF DI RECTIONS OF HONBLE ITAT. WE FURTHER FIND THAT THE ORDER OF LD. CIT(A) IS A N ON SPEAKING ONE WHEREIN HE HAS ALLOWED RELIEF TO THE ASSESSEE AFTER REPRODU CING THE SUBMISSIONS OF THE ASSESSEE. IN VIEW OF THE ABOVE, WE DEEM IT APPROPR IATE TO REMIT THIS MATER BACK TO THE OFFICE OF LD. CIT(A) WHO IS DIRECTED TO PASS SPEAKING ORDER AFTER GIVING PROPER OPPORTUNITY TO A.O. AS PER PROVISIONS OF RULE 46A. 9. IN VIEW OF ABOVE, APPEAL FILED BY THE REVENUE IS ALLOWED FOR STATISTICAL PURPOSES. 10. ORDER PRONOUNCED IN THE OPEN COURT ON 05 TH DEC., 2014. SD./- SD./- ( A. T. VARKEY) (T.S. KAPOOR ) JUDICIAL MEMBER ACCOUNTANT MEMBER DATE: 05 TH DEC., 2014 SP COPY FORWARDED TO:- THE APPELLANT THE RESPONDENT THE CIT THE CIT (A)-, NEW DELHI. THE DR, ITAT, LOKNAYAK BHAWAN, KHAN MARKET, NEW DEL HI. TRUE COPY. BY ORDER (ITAT, NEW DELHI). 9 ITA NO.1190/DEL/2012 S.NO. DETAILS DATE INITIALS DESIGNATION 1 DRAFT DICTATED ON SR. PS/PS 2 DRAFT PLACED BEFORE AUTHOR 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 SR. PS/PS 7 FILE SENT TO BENCH CLERK SR. PS/PS 8 DATE ON WHICH THE FILE GOES TO HEAD CLERK 9 DATE ON WHICH FILE GOES TO A.R. 10 DATE OF DISPATCH OF ORDER