Delhi International Airport Authority (P) Ltd., New Delhi V. CIT-IV, New Delhi

ITA 137/DEL/2012

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 7137 (ITAT-DELHI)
• Duration Of Justice: 6 year(s) 5 month(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 05-07-2018
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Next Hearing Date: 24-05-2017
• Assessment Year: 2007-2008
• Appeal Filed On: 09-01-2012
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Assessment record
• Section: 263; 63

Judgement Text

ITA NO. 137/DEL/2012 1 THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: B NEW DELHI BEFORE SHRI R.S. SYAL, VICE PRESIDENT & SHRI K.N. CHARY, JUDICIAL MEMBER ITA NO. 137/DEL/2012 ( ASSESSMENT YEARS: 2007-08) DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED PAN: AACCD3570F VS COMMISSIONER OF INCOME TAX-IV, DELHI & ASSESSEE BY SH. RONAK G.DOSHI, FCA SH. HARDIK NIRMAL, CA REVENUE BY MS. RACHNA SINGH, CIT DR ORDER PER K. NARSIMHA CHARY, J.M. AGGRIEVED BY THE ORDER DATED 31/10/2011 PASSED BY T HE LD. COMMISSIONER OF INCOME TAX, DELHI-IV, NEW DELHI (LD. CIT) UNDER SECTION 263 OF THE INCOME TAX ACT, 1961 THE ASSESSEE PREFERRED THIS APPEAL. 2. BRIEF FACTS OF THE CASE ARE THAT THE ASSESSEE CO MPANY IS ENGAGED IN DEVELOPING, OPERATING AND MAINTAINING AI RPORT AND RELATED INFRASTRUCTURE AT THE NEW DELHI AIRPORT. FO R THE AY 2007-08, THE ASSESSEE FILED THE RETURN OF INCOME DE CLARING A TOTAL LOSS OF RS. 150,55,30,337/- AND REVISED ITS R ETURN OF INCOME ON 30/03/2009 DECLARING A TOTAL LOSS OF RS. DATE OF HEARING 04.07.2018 DATE OF PRONOUNCEMENT 05.07.2018 ITA NO. 137/DEL/2012 2 149,48,78,939/-. DURING THE SCRUTINY OF THE RETURN OF INCOME, LEARNED ASSESSING OFFICER (LD. AO) MADE CERTAIN A DDITIONS AND DETERMINED THE INCOME OF THE ASSESSEE AT RS. 62,69,55,060/-. 3. HOWEVER, SUBSEQUENTLY, ON EXAMINATION OF THE INC OME TAX ASSESSMENT RECORDS OF THE ASSESSEE, LEARNED CIT FOUND THAT THE ASSESSEE COMPANY HAD RECEIVED PASSENGER SE RVICE FEE (PSF), BUT THE SAME HAS NOT BEEN DISCLOSED AS P ART OF REVENUE RECEIPT AMOUNTING TO RS. 77,06,88,000/-IN T HE RETURN OF INCOME BY THE ASSESSEE; THAT DUE TO THIS OMISSION ON THE PART OF THE ASSESSEE THE INCOME DECLARED FOR TAX FOR ASSESSMENT YEAR 2007-08 FELL SHORT BY RS. 77,06,88, 000/-; THAT CONSEQUENTLY THE ASSESSMENT MADE BY THE AO AL SO BECAME ERRONEOUS RESULTING IN UNDER ASSESSMENT OF T AX, AND ISSUED NOTICE TO THE ASSESSEE. 4. IT WAS SUBMITTED ON BEHALF OF THE ASSESSEE THAT THEY HAD REPRESENTED THEIR CASE BEFORE THE MINISTRY OF CIVIL AVIATION (MOCA) THROUGH ASSOCIATION OF PRIVATE AIRPORTS OPER ATORS (APAO) REGARDING TAXABILITY OF PASSENGER SERVICE FE E (SECURITY COMPONENT) AND IN TURN MOCA HAS ALSO REPRESENTED TH EIR CASE BEFORE THE MINISTRY OF FINANCE, DEPARTMENT OF REVENUE REGARDING TAXABILITY OF THE PASSENGER SERVICE FEE ( SECURITY COMPONENT). IT WAS REPRESENTED BY THE ASSESSEE THAT SINCE THE MATTER WAS SUB JUDICE AND IT MAY TAKE 2-3 MONTHS, F OR THE DISPOSAL OF APPLICATION, THEY REQUESTED TO KEEP THE ADDITION IN THIS MATTER IN ABEYANCE. 5. LD. CIT FOUND THAT FOR ASSESSMENT YEAR 2008-09 T HE ASSESSEE COMPANY RECEIVED PSF BUT DID NOT DISCLOSE THE SAME ITA NO. 137/DEL/2012 3 AS PART OF REVENUE RECEIPT, AS SUCH THE LD. AO ADDE D RS. 80.70 CRORES TO THE INCOME OF THE ASSESSEE BY CONSI DERING THE SAME AS REVENUE RECEIPT ON ACCOUNT OF PSF. HOWEVER, THE ASSESSMENT YEAR 2007-08 A SUM OF RS. 77,06,88,000 W AS RECEIVED AS PSF AND THE SAID AMOUNT WAS NOT DISCLOS ED AS PART OF REVENUE RECEIPT IN THE RETURN OF INCOME FIL ED BY THE ASSESSEE. IN THESE CIRCUMSTANCES, LD. CIT HELD THAT THE ASSESSING OFFICER HAS FAILED TO ASSESS THE REVENUE RECEIPT OF RS. 77,06,88,000/-ON ACCOUNT OF PASSENGER SERVICE F EE FOR THE ASSESSMENT YEAR 2007-08 IN THE REGULAR ASSESSMENT O RDER, AND THEREFORE, SUCH ORDER IS ERRONEOUS AND PREJUDIC IAL TO THE INTEREST OF REVENUE. LD. CIT REFUSED TO KEEP THE MA TTER IN ABEYANCE SINCE NO DECISION OF MOCA WAS COMMUNICATED . LD. CIT, ACCORDINGLY SET ASIDE THE ISSUE AND DIRECTED T HE LD. AO TO REFRAME THE ASSESSMENT BY TAKING INTO ACCOUNT TH E REVENUE RECEIPT ON ACCOUNT OF PASSENGER SERVICE FEE. AGGRIE VED BY THE ORDER UNDER SECTION 263 OF THE ACT, ASSESSEE PREFER RED THIS APPEAL. 6. IT IS THE ARGUMENT OF THE LD. AR THAT THE PASSEN GER SERVICE FEE IS COMPRISED OF TWO COMPONENTS, NAMELY, SECURITY COMPONENT TO THE EXTENT OF 65% AND FACILITATION COM PONENT TO THE EXTENT OF 35%, COLLECTED BY THE RESPECTIVE AIRL INES WHEREIN THE ASSESSEE IS HAVING CONTROL OVER THE 35% ONLY TO MEET THE FACILITIES THAT ARE PROVIDED TO THE PASSENGERS; WHE REAS THE ASSESSEE HAS NO CONTROL WHATSOEVER OVER THE SECURIT Y COMPONENT OF 65%. IT IS FURTHER SUBMITTED THAT THE PASSENGER SERVICE FEE FOR THE TIME BEING IN FORCE IS RS. 200 PER PASSENGER OUT OF WHICH RS. 130/-ACCOUNTS FOR THE SECURITY COM PONENT. IT IS SUBMITTED THAT AS PER THE OPERATION, MANAGEME NT AND ITA NO. 137/DEL/2012 4 DEVELOPMENT AGREEMENT (OMDA) BETWEEN THE AIRPORTS AUTHORITY OF INDIA AND A DELHI INTERNATIONAL AIRPOR T PRIVATE LTD, SECURITY IS A RESERVED ACTIVITY. IT IS FURTHE R SUBMITTED THAT THE STANDARD OPERATING PROCEDURE (SOP) FOR ACCOUNT/AUDIT OF PASSENGER SERVICE FEE PRESCRIBES T HE NATURE OF SECURITY COMPONENT OF PSF AND IT REQUIRES THE OP ENING OF AN ESCROW ACCOUNT WHEREIN THE AIRLINES OPERATORS AR E REQUIRED TO DEPOSIT THE PSF SECURITY COMPONENT IMME DIATELY AFTER COLLECTION. HE FURTHER DRAW OUR ATTENTION TO THIS SOP CLAUSES WHEREIN IT IS STATED THAT THE ESCROW BANK S HALL ALLOW WITHDRAWAL BY JVC/PRIVATE OPERATORS OF AMOUNTS DEPO SITED INTO THE PSF (SC) ACCOUNT ONLY TOWARDS CERTAIN SPEC IFIC PURPOSES IN THE ORDER OF PRIORITY. HE ALSO REFERRED TO CLAUSE (H) OF PARA 3.2 OF THE ESCROW AGREEMENT DATED 12 TO JUN E 2006 WHERE UNDER IT IS STATED THAT THE AMOUNT LYING IN T HE SURPLUS ACCOUNT SHALL BE PAID BY THE ESCROW BANK ONLY TOWAR DS CERTAIN PURPOSES AND IT IS STATED IN THIS AGREEMENT VIDE PARA E OF THE PREAMBLE THAT ANY BALANCE LYING IN THE E SCROW BANK ACCOUNT SHALL BE TRANSFERRED TO THE AAI FOR PAYMENT TO CISF FOR CISF PERSONNEL DEPLOYED/SERVICES PROVIDED BY CI SF AT OTHER AIRPORTS IN AND AROUND INDIA. 7. BASING ON THE RECITALS OF THE OMDA, SOP FOR ACCOUNT/AUDIT OF PASSENGER SERVICE FEE AND THE ESCR OW AGREEMENT HE SUBMITTED THAT THE ASSESSEE HAS NO CON TROL OVER THE FUNDS THAT ARE DEPOSITED IN THE ESCROW ACC OUNT FOR CISF PSF COMPONENT INASMUCH AS IT IS FOR THE EXCLUS IVE PURPOSE OF PURCHASING THE MACHINERY REQUIRED BY THE CISF, PAYMENTS TO BE MADE TO CISF AND THE BALANCE TO BE TRANSFERRED TO AAI FOR PAYMENT TO CISF FOR CISF PER SONNEL ITA NO. 137/DEL/2012 5 DEPLOYED/SERVICES PROVIDED BY CISF AT OTHER AIRPORT S IN AND AROUND INDIA. ACCORDING TO THE ASSESSEE SUCH AN AMO UNT NEVER COMES TO THE BOOKS OF THE ASSESSEE AND THAT W AS REQUIRED TO BE DIRECTLY DEPOSITED IN THE ESCROW ACC OUNT FOR THIS SPECIFIC PURPOSE AND IT IS TO BE SPENT FOR THE PURPOSES SPECIFIED BY THE GOVERNMENT OF INDIA AND THE BALANC E HAS TO BE TRANSFERRED TO THE AAI FOR THE SPECIFIED PURPOSE S. 8. HE BROUGHT TO OUR NOTICE THE ORDER DATED 30/11/2 016 IN ITA NO. 3232/MUM/2012 AND ITA NUMBER 20/07/1960/MUM/2012 FOR THE ASSESSMENT YEAR 2008-09 IN THE CASE OF THE MUMBAI INTERNATIONAL AIRPORTS PRIVA TE LIMITED AND SUBMITTED THAT THE VERY SIMILAR ISSUE WAS INVOL VED IN THAT CASE ALSO AND IT WAS HELD THAT THE ESCROW ACCOUNT MAINTAINED BY THE ASSESSEE IS SIMPLY A POOL CREATED BY THE MOCA THROUGH THE ASSESSEE FOR PERMITTING SECURITY E XPENSES; THAT IF ANY INCOME CAN BE COMPUTED, THAT WOULD BE P OSSIBLE ONLY IF ANY SURPLUS ARISES, WHICH IS NOT POSSIBLE T O HAPPEN SINCE ENTIRE AMOUNT COLLECTED BY THE ASSESSEE COMPA NY HAS TO BE DEPOSITED IN ESCROW ACCOUNT WHICH IS EARMARKED W HOLLY AND EXCLUSIVELY PERMITTING SECURITY EXPENSES; THAT THERE IS NO FLEXIBILITY FOR USING THE FUNDS ELSEWHERE; THAT IF IT ANY AMOUNT IS LEFT UNSPENT FROM THIS ACCOUNT, THEN THE SAME HA S TO BE TRANSFERRED TO THE ACCOUNT OF AIRPORT AUTHORITY OF INDIA PERMITTING SECURITY EXPENSES, AS SUCH THERE IS NO Q UESTION OF THERE BEING ANY INCOME IN THIS EXERCISE MUCH LESS A NY INCOME WHICH COULD BE CHARACTERISED AS TAXABLE INCOME IN T HE HANDS OF THE ASSESSEE COMPANY. ITA NO. 137/DEL/2012 6 9. BASING ON THESE FACTS AND CIRCUMSTANCES, IT IS A RGUED BY THE LD. AR THAT THE SECURITY COMPONENT OF THE PSF I S NOT INCOME IN THE HANDS OF THE ASSESSEE AS IS HELD BY T HE MUMBAI TRIBUNAL IN THE ABOVE REFERRED CASE. HE FURTHER SUB MITTED THAT IN ANY CASE IT IS A CONTENTIOUS ISSUE NOT AMEN ABLE TO THE JURISDICTION OF THE LEARNED CIT UNDER SECTION 263 O F THE ACT. 10. PARA CONTRA, IT IS THE ARGUMENT OF THE LD. DR T HAT IN THE OFFICIAL MEMORANDUM DATED 30/06/2006 ISSUED BY THE CENTRAL BOARD OF DIRECT TAXES(CBDT), DEPARTMENT OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA I T IS CLEARLY HELD THAT THE STATUTORY LEVIES COLLECTED BY AN ASSESSEE IN THE COURSE OF ITS BUSINESS TO BE EVENTUALLY TURN ED OVER TO THE GOVERNMENT IS INCOME WITHIN THE MEANING OF THE INCOME TAX ACT (CHOWRINGHEE SALES BUREAU PRIVATE LIMITED V S. CIT (87 ITR 542, 548; (SC)) AND IN VIEW OF THIS DECISIO N OF THE HONBLE SUPREME COURT THE PSF CONSTITUTES INCOME WI THIN THE MEANING OF THE INCOME TAX ACT. THE CBDT BY DRAW ING ANALOGY FROM SECTION 43 B OF THE ACT HELD THAT THE WHOLE OF THE AMOUNT OF PSF SHALL BE TREATED AS INCOME AND TH EREAFTER THE DEDUCTIONS ARE PERMISSIBLE ONLY IN RESPECT OF T HE EXPENSES ACTUALLY MADE. BASING ON THIS OFFICIAL MEM ORANDUM LD. DR SUBMITTED THAT THOUGH THE CBDT CIRCULAR DOES NOT BIND THE TRIBUNAL OR JUDICIAL AUTHORITIES, IT WOULD CERTAINLY BIND THE LD. AO. SINCE THE LD. AO FAILED TO FOLLOW THIS CIRCULAR, IT RESULTED IN ESCAPEMENT OF INCOME WITHI N THE MEANING OF THIS OFFICIAL MEMORANDUM AND ON THE PREM ISE LD. DR JUSTIFIED THE IMPUGNED ORDER. ITA NO. 137/DEL/2012 7 11. LD. DR BROUGHT TO OUR NOTICE THE CONTENTS OF TH E ASSESSMENT ORDER IN THIS CASE TO DEMONSTRATE THAT A BSOLUTELY THERE IS NO REFERENCE TO PSF OR ANY ENQUIRY CONDUCT ED BY THE LD. AO IN THAT DIRECTION. SHE, THEREFORE, SUBMITS T HAT UNDER EXPLANATION 2 TO SECTION 263 OF THE ACT, THIS ORDER PASSED WITHOUT MAKING ENQUIRIES ARE VERIFICATION THAT WAS SUPPOSED TO BE DONE IN VIEW OF THE ABOVE CBDT CIRCULAR, IS E RRONEOUS INSOFAR AS IT IS PREJUDICIAL TO THE INTEREST OF THE REVENUE. 12. LD. DR FURTHER PLACED RELIANCE ON THE DECISION OF THE HONBLE APEX COURT IN CHOWRINGHEE SALES BUREAU PRIV ATE LIMITED VS. CIT (SUPRA) AND SUBMITTED THAT THE PSF CONSTITUTES INCOME WITHIN THE MEANING OF INCOME TAX ACT AND THAT FOR WANT OF PROPER ENQUIRY ON THE PART OF THE LD. AO, LEARNED CIT IS JUSTIFIED IN REVISING THE SAME UNDER SECTION 263 OF THE ACT. 13. SHE FURTHER BROUGHT TO OUR NOTICE THE ORDER DAT ED 31/01/2018 IN ITA NUMBERS 2636, 4213/DEL/2012 AND 3707/DEL/2013 FOR ASSESSMENT YEARS 2008-09 TO 2010- 11 IN ASSESSEES OWN CASE WHEREIN A COORDINATE BENCH OF T HIS TRIBUNAL HELD THAT THE FACTS RELATING TO THE DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED (SUPRA) ARE SLIGHTLY DIFFER ENT FROM THE FACTS INVOLVED IN THE CASE OF MUMBAI INTERNATIONAL AIRPORT LTD AND THAT A COORDINATE BENCH OF THIS DAILY TRIBUNAL REMANDED THE MATTER TO THE LD. ASSESSING OFFICER FOR VERIFIC ATION AS TO THE APPROPRIATION OF THE DIVIDEND AMOUNT AND THE TR EATMENT GIVEN TO THE SURPLUS AMOUNT. SHE, THEREFORE, SUBMIT S THAT IN VIEW OF THE DIFFERENCE IN FACTS AS NOTED BY THE COO RDINATE BENCH OF THIS TRIBUNAL IN ASSESSEES OWN CASE, THE DECISION IN ITA NO. 137/DEL/2012 8 MUMBAI INTERNATIONAL AIRPORTS CASE (SUPRA) CANNOT B E FOLLOWED. 14. THE SUM AND SUBSTANCE OF THE ARGUMENT OF LD. DR IS THAT THE PROPER COURSE FOR THE ASSESSEE WAS TO DECL ARE THE INCOME RELATING TO THE PSF SECURITY COMPONENT ALSO AS INCOME AND THEN TO CLAIM THE DEDUCTIONS IN CONSONAN CE WITH THE OFFICIAL MEMORANDUM DATED 30/06/2008 ISSUED BY THE CBDT IN THE LIGHT OF THE DECISION OF THE HONBLE AP EX COURT IN CHOWRINGHEE SALES BUREAU PRIVATE LIMITED (SUPRA). W ITH THIS VIEW OF THE MATTER LD. DR PRAYED TO DISMISS THE APP EAL AND TO UPHOLD THE EXERCISE OF JURISDICTION UNDER SECTION 2 63 OF THE ACT BY THE LEARNED CIT. 15. WE HAVE CAREFULLY GONE THROUGH THE RECORD. THE OMDA IS CLEAR THAT THE SECURITY IS A RESERVED ACTIVITY A ND OUT OF RS. 200/-COLLECTED BY THE AIRLINER, RS. 130/-RELATED TO THE PSF SECURITY COMPONENT. FURTHER THE SOP FOR ACCOUNT/AUD IT OF PASSENGER SERVICE FEE STIPULATES THAT THERE SHALL B E AN ESCROW ACCOUNT AND THE ESCROW BANK SHALL ALLOW THE WITHDRA WAL BY THE JVC/PRIVATE OPERATORS OF AMOUNTS DEPOSITED INTO THE PSF (SC) ACCOUNT ONLY TOWARDS CERTAIN PURPOSES THAT TOO TO IN THE ORDER OF PRIORITY BY DESCENDING ORDER. THE ESCROW A GREEMENT DATED 12/06/2006 CLEARLY ESTABLISHES THAT THE WITHD RAWAL FROM THE SURPLUS ACCOUNT ARE PERMISSIBLE ONLY IN SE VEN CASES FOR SPECIFIED PURPOSES AND WHATEVER THE BALANCE THA T REMAINS IN SUCH ESCROW ACCOUNT SHALL BE TRANSFERRED TO AAI FOR PAYMENT OF CISF FOR CISF PERSONNEL DEPLOYED/SERVICE S PROVIDED BY CISF AT OTHER AIRPORTS IN AND AROUND IN DIA. ITA NO. 137/DEL/2012 9 16. HAVING GONE THROUGH THE OMDA AGREEMENT, SOP AND THE ESCROW AGREEMENT IN THE LIGHT OF OTHER RELEVANT PAPERS FURNISHED IN THE PAPER BOOK WE ARE CONVINCED THAT P RIMA FACIE THERE APPEARS TO BE NO CONTROL FOR THE ASSESS EE OVER THE SECURITY COMPONENT OF THE PSF COLLECTED BY THE AIRL INER AND DEPOSITED INTO THE ESCROW ACCOUNT MEANT TO MAKE THE SECURITY PURPOSES. 17. FURTHER WE HAVE GONE THROUGH THE ORDERS OF THE MUMBAI TRIBUNAL IN THE CASE OF MUMBAI INTERNATIONAL AIRPOR T PRIVATE LIMITED (SUPRA) AND A COORDINATE BENCH OF THE DELHI TRIBUNAL IN ASSESSEES OWN CASE (SUPRA). IN THE FORMER CASE THE TRIBUNAL RETURNED A FINDING THAT THE SECURITY COMPO NENT OF THE PSF AMOUNT DOES NOT CONSTITUTE INCOME IN THE HA NDS OF THE ASSESSEE WHEREAS SUCH AN ISSUE HAS BEEN REMANDE D BACK TO THE LD. AO BY THE DELHI TRIBUNAL. IT IS, THEREFO RE, CLEAR THAT THE QUESTION WHETHER OR NOT THE SECURITY COMPONENT OF THE PSF CONSTITUTES INCOME IN THE HANDS OF THE ASSESSEE S HAS NOT YET FINALLY BEEN DECIDED AUTHORITATIVELY. IT STILL REMAINS A CONTENTIOUS ISSUE AND A DEBATABLE ONE. 18. IN THESE CIRCUMSTANCES, WE ARE OF THE CONSIDERE D OPINION THAT IN VIEW OF THE DECISION OF THE HONBLE APEX CO URT IN M/S MALABAR INDUSTRIES CO LTD. VS. CIT [2000] 243 ITR 8 3 (SC), SUCH CONTENTIONS OR DEBATABLE ISSUES ARE NOT AVAILA BLE FOR REVISION UNDER SECTION 263 OF THE ACT. WITH THIS VI EW OF THE MATTER, WE FIND THAT IN THIS SET OF FACTS AND CIRCU MSTANCES, THE EXERCISE OF JURISDICTION UNDER SECTION 263 OF T HE ACT BY THE LEARNED CIT CANNOT BE SUSTAINED. WE THEREFORE A LLOW THE ITA NO. 137/DEL/2012 10 GROUNDS OF APPEAL AND QUASH THE IMPUGNED ORDER PASS ED UNDER SECTION 263 OF THE ACT. 19. IN THE RESULT APPEAL OF THE ASSESSEE IS ALLOWED . ORDER PRONOUNCED IN THE OPEN COURT ON 05.07.2018 SD/- SD/- (R.S. SYAL) (K. NARSIMHA CHAR Y) VICE PRESIDENT JUDICIAL ME MBER DATED: 05.07.2018 COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT TRUE COPY ASSISTANT REGISTRAR ITAT NEW DELHI DATE OF DICTATION 03.07.2018 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 03.07.2018 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE OTHER MEMBER DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR. P S/PS 06.07.18 DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE D ICTATING MEMBER FOR PRONOUNCEMENT 05.07.18 DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR. PS/PS 06.07.18 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WE BSITE OF ITAT 06.07.18 DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 06.0 7.18 DATE ON WHICH THE FILE GOES TO THE HEAD CLERK THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT RE GISTRAR FOR SIGNATURE ON THE ORDER DATE OF DISPATCH OF THE ORDER