Mangalbhai Hargovandas Patel, Gandhinagar V. The ITO, Ward-5, Gandhinagar

ITA 1532/AHD/2019

• Counselvise Citation: [2021] 108 COUNSELVISE.COM (IT) 9710 (ITAT-AHMEDABAD)
• Duration Of Justice: 1 year(s) 5 month(s) 11 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-03-2021
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2013-2014
• Appeal Filed On: 07-10-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: S S SHUKLA
• Assessee Lawyers: DIVYAY J SHAH
• Keywords: Sale consideration of property below Jantri Value; Opportunity of being heard; Fair market value; Capital Gains
• Section: 50C; 148; 144

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL SMC BENCH, AHMEDABAD (CONDUCTED THROUGH VIRTUAL COURT) BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER & MS. MADHUMITA ROY, JUDICIAL MEMBER I.T.A. NO. 1532/AHD/2019 (ASSESSMENT YEAR: 2013-14) MANGALBHAI HARGOVANDAS PATEL 60, KRISHNAGAR PARU, PADUSMA, TAL-MANSA, GANDHINAGAR-382845 VS. ITO WARD-5, GANDHINAGAR PAN NO. BJXPP2222E ( APPELLANT ) .. ( RESPONDENT ) APPELLANT BY : MS. DIVYAY J. SHAH, AR RESPONDENT BY : SHRI S. S. SHUKLA , SR. DR DATE OF HEARING 18.01.2021 DATE OF PRONOUNCEMENT 18.03.2021 O R D E R PER MS. MADHUMITA ROY - JM: THE INSTANT APPEAL FILED BY THE ASSESSEE IS DIRECT ED AGAINST THE ORDER DATED 07.08.2019 PASSED BY THE COMMISSIONER O F INCOME TAX (APPEALS) GANDHINAGAR, AHMEDABAD ARISING OUT OF THE ASSESSMENT ORDER DATED 28.12.2017 PASSED BY THE ITO, WARD-3, GANDHIN AGAR UNDER SECTION 144 R.W.S 147 OF THE INCOME TAX ACT, 1961 (HEREINAF TER REFERRED AS TO THE ACT) FOR ASSESSMENT YEAR 2013-14. 2. THE BRIEF FACTS LEADING TO THE CASE IS THIS THAT THE APPELLANT HAS SOLD AN IMMOVABLE PROPERTY OF RS. 50,00,000/- AND ALSO D EPOSITED CASH OF RS. ITA NO.1532/AHD/2019 MANGALBHAI HARGOVANDAS PATEL VS. ITO ASST.YEAR 2013-14 - 2 - 4,50,000/- IN HIS BANK ACCOUNT. UPON GETTING SUCH INFORMATION THE CASE WAS REOPENED UNDER SECTION 148 OF THE ACT BY ISSUIN G NOTICE FOLLOWED BY A SHOW-CAUSE NOTICE DATED 31.10.2017 PROPOSING ADDI TION OF RS. 28,22,115/- BEING THE 34% SHARE OF THE WORKED OUT S HORT-TERM CAPITAL GAIN IN RESPECT OF THE CO-OWNED PROPERTY WHICH WAS PURCHASED ON 02.08.2010 AND SOLD ON 19.06.2012. IT IS RELEVANT TO MENTION THAT THE SAID AGRICULTURAL LAND SITUATED AT PETHAPUR VILLAGE BEAR ING SURVEY NO. 6 AND ADMEASURING 6767 SQ. MTRS. WAS TRANSFERRED BY THE A PPELLANT BY WAY OF SALE DEED REGISTERED AT SR. NO. 8220 ON 20.06.2012 BEFORE THE OFFICE OF THE SUB-REGISTRAR AT GANDHINAGAR. THE CONSIDERATIO N AS REFLECTED IN THE SALE DEED WAS 50,00,000/- AND THE LAND WAS CO-OWNED BY THE APPELLANT WITH SHRI GOVINDBHAI MAGANBHAI PATEL AND SHRI HARES HBHAI RAMANBHAI PATEL WHICH WAS ULTIMATELY SOLD TO ONE SHRI ARJUNJI MAHOTJI GOHIL AND 04 OTHERS. THE SAID REASSESSMENT PROCEEDING WAS ULTIM ATELY FINALIZED WITH AN ADDITION OF RS. 28,22,726/- ON ACCOUNT OF SHORT- TERM CAPITAL GAIN IN THE HANDS OF THE ASSESSEE. DURING THE PENDENCY OF THE APPEAL THE APPELLANT MADE A REQUEST BEFORE THE LD. CIT(A) TO MAKE A REFE RENCE TO THE DEPARTMENT VALUATION CELL FOR DETERMINING THE FAIR MARKET VALUE OF THE PROPERTY IN QUESTION WHICH WAS NOT TAKEN INTO CONSI DERATION BY THE LD. CIT(A) AND THE ORDER OF ADDITION TO THE TUNE OF RS. 28,22,726/- ON ACCOUNT OF SHORT-TERM CAPITAL GAIN HAS BEEN CONFIRM ED BY THE LD. CIT(A). 3. THE LD. COUNSEL APPEARING FOR THE ASSESSEE SUBMI TTED BEFORE US THAT THE AO ERRED IN ADOPTING STAMP DUTY VALUATION OF RS. 1,11,67,347/- UNDER SECTION 50C OF THE ACT AND FURTHER MAKING ADD ITION OF RS. 28,22,726/- AS CAPITAL GAIN. HE ULTIMATELY ARGUED ON THIS PARTICULAR POINT ITA NO.1532/AHD/2019 MANGALBHAI HARGOVANDAS PATEL VS. ITO ASST.YEAR 2013-14 - 3 - THAT IN SPITE OF REQUEST MADE BEFORE THE LD. CIT(A) FOR REFERRING THE MATTER TO THE DEPARTMENTAL VALUATION OFFICER (DVO) FOR DETERMINATION OF THE VALUATION OF THE PROPERTY IN QUESTION IN TERMS OF THE SECTION 50C OF THE ACT THE SAME WAS NOT CONSIDERED IN ITS PROPER P ERSPECTIVE. THE LD. COUNSEL FURTHER DREW OUR ATTENTION TO THE WRITTEN S UBMISSION-II MADE BEFORE THE LD. CIT(A) GANDHINAGAR WHEREFROM IT REFL ECTS THAT REQUEST WAS DULY MADE BEFORE THE LD. CIT(A) TO DETERMINE VA LUE BY THE DEPARTMENTAL VALUATION OFFICER(DVO) AS PER SECTION 50C(2) OF THE ACT. HE, THEREFORE, PRAYS FOR SETTING ASIDE THE ISSUE TO THE LD. AO WITH A FURTHER DIRECTION UPON HIM TO REFER THE MATTER TO T HE DVO FOR DETERMINING THE VALUATION OF THE PROPERTY IN QUESTION IN TERMS OF THE SECTION 50C OF THE ACT. IN THIS REGARD, HE ALSO RELIED UPON TWO JUDGMENTS PASSED BY THE CO- ORDINATE BENCH IN ITA NO. 2087/AHD/2013 (NARENDRA D AHYABHAI PATEL VS. ITO) AND ITA NO. 782/AHD/2017 (PRANAY N VORA VS . ITO). WHILE DEALING WITH THE ISSUE IN THE CASE OF PRANAY N. VORA VS. ITO THE LD. CO-ORDINATE BENCH HAS BEEN PLEASED TO OBSER VE AS FOLLOWS:- 6. WE HAVE HEARD THE LEARNED REPRESENTATIVES OF TH E PARTIES AND PERUSED THE MATERIAL AVAILABLE ON RECORD. WE FIND THAT IT IS MA NDATORY ON THE PART OF THE ASSESSING OFFICER TO REFER THE MATTER TO THE DVO, E VEN IF IT IS NOT ASKED BY THE ASSESSEE BEFORE THE AUTHORITIES BELOW, BEFORE COMPU TATION OF CAPITAL GAINS UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE IN HAND AS DECI DED BY NUMBER OF JUDGMENTS PASSED BY THE CO-ORDINATE BENCH OF THIS TRIBUNAL, T HE HONBLE JURISDICTIONAL HIGH COURT AS WELL AS HONBLE HIGH COURT OF CALCUTTA, WH ICH THE ASSESSING OFFICER HAS FAILED TO DO. THE RELEVANT PORTION OF THE JUDGMENTS PASSED BY THE CO-ORDINATE BENCH OF THIS TRIBUNAL, AS RELIED UPON BY THE REPRESENTAT IVE OF THE ASSESSEE, ARE AS FOLLOWS:- (I) TARUN MANMOHAN GARG VS. DCIT IN ITA NO.3208/AH D/2015 FOR AY 2011- 12, ORDER DATED 22.08.2017 ITA NO.1532/AHD/2019 MANGALBHAI HARGOVANDAS PATEL VS. ITO ASST.YEAR 2013-14 - 4 - 2. LEARNED REPRESENTATIVES FAIRLY AGREE THAT WHATE VER WE DECIDE IN ITA NO.3207/AHD/2015 IN THE CASE OF MANMOHAN RAJARAM GA RG VS. DCIT FOR THE ASSESSMENT YEAR 2011-12, WHICH WE HAD HEARD ALONG W ITH THIS APPEAL, WILL APPLY MUTATIS MUTANDIS FOR THIS APPEAL AS WELL, AS THE ISSUE RAISED IN THIS APPEAL IS IDENTICAL TO THAT OF ITA NO.3207/AHD/2015 IN THE CASE OF MANMOHAN RAJARAM GARG FOR THE ASSESSMENT YEAR 2011- 12. VIDE MY ORDER OF EVEN DATE, I HAVE ALLOWED THE SAME ISSUE FOR STA TISTICAL PURPOSES IN THE CASE OF MANMOHAN RAJARAM GARG IN ITA NO.3207/AHD/20 15, AND THE SAME RESULT MUST FOLLOW HERE AS WELL. IN MY SAID ORDER, I HAVE, INTER ALIA, OBSERVED AS FOLLOWS: 2. WHEN THIS APPEAL WAS CALLED OUT FOR HEARING, LE ARNED COUNSEL FOR THE ASSESSEE INVITED OUR ATTENTION TO ORDER DATED 3 1ST AUGUST 2016, PASSED BY THIS TRIBUNAL, IN THE CASE OF NARENDRA DA HYABHAI PATEL VS. ITO IN ITA NO.2087/AHD/2013, BY WHICH THE ISSUE IN APPEAL BEFORE ME IS SAID TO BE COVERED. LEARNED COUNSEL SUBMITS T HAT THE SHORT ISSUE REQUIRING OUR ADJUDICATION IN THIS CASE IS WH ETHER OR NOT, IN THE ABSENCE OF A SPECIFIC REQUEST MADE BY THE ASSESSEE DURING THE ASSESSMENT PROCEEDINGS FOR REFERENCE BEING MADE TO THE DVO UNDER SECTION 50C, SUCH REFERENCE COULD BE DIRECTED BY TH E APPELLATE AUTHORITIES. IN THIS CONNECTION, SHE INVITES MY ATT ENTION TO THE FOLLOWING OBSERVATIONS MADE BY THE TRIBUNAL IN THE CASE OF NARENDRA DAHYABHAI PATEL VS. ITO (SUPRA). 2. IT IS A CASE IN WHICH THE ASSESSING OFFICER HAS ADOPTED STAMP DUTY VALUATION OF THE PROPERTY SOLD, FOR COMPUTATIO N OF CAPITAL GAINS, UNDER SECTION 50C OF THE INCOME TAX ACT, 1961. IN A PPEAL BEFORE THE LEARNED CIT(A), THE ASSESSEES CONTENTION WAS THAT DESPITE HIS REQUEST, THE MATTER WAS NOT REFERRED TO DVO UNDER S ECTION 50C(2) BUT THE APPEAL WAS TURNED DOWN ON THE GROUND THAT A SSESSEE COULD NOT SUBSTANTIATE HIS CLAIM OF HAVING MADE SUCH A RE QUEST IN THE COURSE OF ASSESSMENT PROCEEDINGS. THE ASSESSEE IS N OT SATISFIED AND IS IN FURTHER APPEAL BEFORE ME. 3. I HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIAL ON RECORD AND DULY CONSIDERED FACTS OF THE CASE IN THE LIGHT OF THE APPLICABLE LEGAL POSITION. 4. I FIND THAT, AS HELD BY HONBLE CALCUTTA HIGH CO URT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT [(2015) 372 ITR 83 (CAL ], EVEN IN THE ABSENCE OF SPECIFIC REQUEST FROM THE ASSESSEE, THE ASSESSING OFFICER HAS TO GIVE AN OPTION TO THE ASSESSEE TO FOLLOW THE COURSE PROVIDED BY LAW UNDER SECTION 50C(2). I, THEREFORE, UPHOLD THE GRIEVANCE OF THE ASSESSEE, AND REMIT THE MATTER TO THE FILE OF THE A SSESSING OFFICER FOR ADJUDICATION DE NOVO AFTER REFERRING THE MATTER TO THE DVO UNDER SECTION 50C(2). ITA NO.1532/AHD/2019 MANGALBHAI HARGOVANDAS PATEL VS. ITO ASST.YEAR 2013-14 - 5 - 3. LEARNED COUNSEL SUBMITS THAT AS THE APPEAL CAN B E DISPOSED OF ON THE ABOVE SHORT GROUND, IT IS NOT REALLY NECESSARY TO D EAL WITH OTHER ASPECTS OF THE MATTER. SHE THUS URGES ME TO REMIT THE MATTER T O THE FILE OF ASSESSING OFFICER WITH THE DIRECTION TO REFER THE MATTER TO T HE DVO UNDER SECTION 50C(2). 4. LEARNED DEPARTMENTAL REPRESENTATIVE DOES NOT DIS PUTE THE FACT THAT THE ISSUE IS SQUARELY COVERED BY THE AFORESAID DECISION OF THE TRIBUNAL BUT POINTS OUT THAT NO SUCH REQUEST FOR REFERENCE TO DVO WAS M ADE BY THE ASSESSEE IN THE COURSE OF ASSESSMENT PROCEEDINGS. HE THUS RELIE S UPON THE ORDERS OF THE AUTHORITIES BELOW. 5. I HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIAL ON RECORD AND DULY CONSIDERED FACTS OF THE CASE IN THE LIGHT OF T HE APPLICABLE LEGAL POSITION. I FIND THAT AS NOTED BY THE TRIBUNAL IN THE CASE OF NARENDRA DAHYABHAI PATEL VS. ITO (SUPRA) THE LAW IS NOW WELL SETTLED THAT EV EN IN THE ABSENCE OF A SPECIFIC REQUEST FROM THE ASSESSEE, THE A.O. HAS TO GIVE AN OPTION TO THE ASSESSEE TO FOLLOW THE COURSE PROVIDED BY LAW UNDER SECTION 50C(2). THERE IS A DIRECT DECISION TO THIS EFFECT BY HONBLE CALCUTT A HIGH COURT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT [(2015) 372 ITR 83 (CAL ]. NO JUDICIAL PRECEDENCE TO THE CONTRARY HAS BEEN BROUGHT TO MY N OTICE. RESPECTFULLY FOLLOWING THE ESTEEMED VIEW OF THE HONBLE CALCUTTA HIGH COURT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT (SUPRA), I UPHOLD TH E PLEA OF THE ASSESSEE AND REMIT THE MATTER TO THE FILE OF ASSESSING OFFIC ER FOR ADJUDICATION DENOVO AFTER REFERRING THE MATTER TO THE DVO UNDER SECTION 50C(2). AS THE MATTER HAS BEEN REMITTED TO THE FILE OF ASSESSING OFFICER WITH THE ABOVE DIRECTIONS, IT IS NOT REALLY NECESSARY TO DEAL WITH OTHER ASPECTS OF THE MATTER. 3. RESPECTFULLY FOLLOWING THE VIEWS SO TAKEN BY ME IN THE CASE OF MANMOHAN RAJARAM GARG VS. DCIT (ITA NO.3207/AHD/2015) FOR AS SESSMENT YEAR 2011- 12, THE ISSUE RAISED BY THE ASSESSEE IN THIS APPEAL IS ALSO ALLOWED FOR STATISTICAL PURPOSES. (II) SARITA SANGAM SOCIETY VS. DCIT IN ITA NO.3562/ AHD/2016 FOR AY 2013-14, ORDER DATED 16.05.2018 5. AS A PLAIN READING OF SECTION 50C(2) SHOWS, WHE N THE ASSESSEE CLAIMS BEFORE ANY ASSESSING OFFICER THAT THE VALUE ADOPTED OR ASSESSED OR ASSESSABLE BY THE STAMP VALUATION AUTHORITY EXCEEDS THE FAIR MARKET VALUE OF THE PROPERTY, THE ASSESSING OFFICER MAY REFER THE VALUATION OF THE PROPERTY TO THE DEPARTMENTAL VALUATION OFFICER. CLEARLY, THE REFORE, A SPECIFIC REQUEST FOR REFERENCE TO THE DEPARTMENTAL VALUATION OFFICER IS NOT AT ALL REQUIRED TO BE MADE BY THE ASSESSEE, AND ALL THAT IS REQUIRED T O INVOKE THE REFERENCE TO THE DEPARTMENTAL VALUATION OFFICER IS A DISPUTE BEI NG RAISED ON VALUATION AS PER STAMP DUTY VALUATION AUTHORITY. IN ANY EVENT, A S IS THE SETTLED LEGAL POSITION IN THE LIGHT OF HONBLE CALCUTTA HIGH COUR TS JUDGMENT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT (GA NO.3686/2013; JU DGEMENT DATED 13TH MARCH 2014) EVEN IN A CASE WHERE NO SUCH PRAYER IS MADE BY THE ASSESSEE ITA NO.1532/AHD/2019 MANGALBHAI HARGOVANDAS PATEL VS. ITO ASST.YEAR 2013-14 - 6 - THE ASSESSING OFFICER, DISCHARGING A QUASI JUDIC IAL FUNCTION HAS THE BOUNDEN DUTY TO ACT FAIRLY AND TO GIVE A FAIR TREAT MENT BY GIVING HIM AN OPTION TO FOLLOW THE COURSE PROVIDED BY THE LAW. IN THE LIGHT OF THESE DISCUSSIONS, AS ALSO BEARING IN MIND ENTIRETY OF TH E CASE, WE DEEM IT FIT AND PROPER TO REMIT THE MATTER TO THE FILE OF THE ASSES SING OFFICER WITH A DIRECTION TO REFER THE VALUATION OF PROPERTY TO THE DEPARTMEN TAL VALUATION OFFICER, AND TO FRAME THE FRESH ASSESSMENT IN THE LIGHT OF, INTE R ALIA, DEPARTMENTAL VALUATION OFFICERS REPORT, IN ACCORDANCE WITH THE LAW, AFTER AFFORDING AN OPPORTUNITY OF HEARING TO THE ASSESSEE AND BY WAY O F A SPEAKING ORDER. THE MATTER THUS STANDS RESTORED TO THE FILE OF THE ASSE SSING OFFICER IN THE TERMS INDICATED ABOVE. 6. AS WE PART WITH THE MATTER, WE MAY ADD THAT THER E IS APPARENTLY ALSO A DISPUTE WITH RESPECT OF THE POINT OF TIME AS TO WHI CH STAMP DUTY VALUATION IS TO BE ADOPTED - AT THE POINT OF TIME WHEN AGREEMENT TO SELL WAS FINALIZED OR WHEN SALE DEED WAS REGISTERED. THIS ASPECT OF THE M ATTER IS NOT REALLY RELEVANT AT PRESENT AS THE MATTER STANDS RESTORED T O THE ASSESSING OFFICER FOR THE PURPOSE OF DEPARTMENTAL VALUATION OFFICERS VAL UATION. HOWEVER, SUFFICE TO ADD, WHILE EXAMINING THIS ASPECT OF THE MATTER, THE ASSESSING OFFICER WILL TAKE INTO ACCOUNT BINDING JUDICIAL PRECEDENTS ON TH E ISSUE, INCLUDING IN THE CASE OF DHARMASHI BHAI SONANI VS. ACIT [(2016) 161 ITD 627 (AHD)]. WE LEAVE IT THAT FOR THE TIME BEING. 7. CONSIDERING THE ENTIRE ASPECT OF THE MATTER AND RESPECTFULLY FOLLOWING THE JUDGMENTS PASSED BY THE CO-ORDINATE BENCH OF THIS T RIBUNAL (SUPRA), WE ARE OF THE VIEW THAT THE MATTER BE REMITTED TO THE FILE OF THE ASSESSING OFFICER FOR ADJUDICATION OF THE SAME DE NOVO UPON MAKING REFERENCE TO THE DVO A ND TO COMPLETE THE ASSESSMENT ON THE BASIS OF THE VALUATION SO RECEIVED FROM THE DVO. WE PASS ORDERS ACCORDINGLY AND DIRECT THE ASSESSING OFFICER TO DECIDE THE MATT ER AFRESH ON THE BASIS OF THE VALUATION TO BE MADE BY THE DVO BY PASSING A SPEAKI NG ORDER IN ACCORDANCE WITH LAW UPON GIVING A REASONABLE OPPORTUNITY OF HEARING TO THE ASSESSEE. 8. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALL OWED FOR STATISTICAL PURPOSES. 4. IT APPEARS FROM THE JUDGMENT NARRATED HEREINBEFO RE AND ALSO OTHER JUDICIAL PRONOUNCEMENTS ON THIS ISSUE THAT IT IS MA NDATORY ON THE PART OF THE AO TO REFER THE MATTER TO THE DVO UNDER SECTION 50C(2) OF THE ACT, EVEN IF IT IS NOT REQUESTED BY THE ASSESSEE BEFORE THE AUTHORITIES BELOW. IF THAT VIEW HAS BEEN TAKEN BY THE DIFFERENT JUDICIAL FORUM THEN THOUGH ADMITTEDLY THE SAID PLEA WAS NOT TAKEN BEFORE THE A O REJECTION OF SUCH REQUEST MADE BEFORE THE LD. CIT(A) IS PALPABLY BAD IN VIEW OF SECTION ITA NO.1532/AHD/2019 MANGALBHAI HARGOVANDAS PATEL VS. ITO ASST.YEAR 2013-14 - 7 - 50C OF THE ACT AND IN THAT VIEW OF THE MATTER RESPE CTFULLY RELYING UPON THE JUDICIAL PRONOUNCEMENTS WE DO NOT HESITATE TO D ELETE THE ADDITION MADE BY THE LD. CIT(A). HOWEVER, WE FIND IT FIT AN D PROPER TO REMIT THE ISSUE TO THE FILE OF THE LD. AO WITH A FURTHER DIRE CTION UPON HIM TO MAKE FRESH ASSESSMENT UPON MAKING REFERENCE OF THE MATTE R TO THE DVO AND TO COMPLETE THE ASSESSMENT ON THE BASIS OF THE VALUATI ON SO RECEIVED FROM THE DVO UPON GIVING AN OPPORTUNITY OF BEING HEARD T O THE ASSESSEE. 5. IN THE RESULT, ASSESSEES APPEAL IS ALLOWED FOR STATISTICAL PURPOSES. THIS ORDER PRONOUNCED IN OPEN COURT ON 1 8 / 0 3 /20 2 1 SD/- SD/- (WASEEM AHMED) (MS. MADHUMITA ROY) ACCOUNTANT MEMBER JUDICIAL MEMBER AHMEDABAD; DATED 18/03/2021 TANMAY, SR. PS TRUE COPY / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. / CONCERNED CIT 4. ( ) / THE CIT(A)- 5. , ! ' , #$%% / DR, ITAT, AHMEDABAD 6. &' () / GUARD FILE. / BY ORDER, / (DY./ASSTT. REGISTRAR) !, #$ / ITAT, AHMEDABAD 1. DATE OF DICTATION 18.01.2021 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 19.01.2021 3. OTHER MEMBER 4. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR.P. S./P.S .01.2021 5. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE D ICTATING MEMBER FOR PRONOUNCEMENT .01.2021 6. DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR.P .S./P.S .03.2021 7. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 18 .03.2021 8. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK ... 9. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT RE GISTRAR FOR SIGNATURE ON THE ORDER.. 10. DATE OF DESPATCH OF THE ORDER