Asst. Commissioner of Income Tax, Circle-15(2), Hyderabad V. M/s Visakhapatnam Industrial Water Supply Company Limited, Visakhapatnam

ITA 1707/HYD/2013

• Counselvise Citation: [2016] 131 COUNSELVISE.COM (IT) 6287 (ITAT-HYDERABAD)
• Duration Of Justice: 2 year(s) 8 month(s) 18 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-08-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Next Hearing Date: 27-06-2016
• Assessment Year: 2007-2008
• Appeal Filed On: 06-12-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: T VENKAT REDDY
• Assessee Lawyers: S RAMA RAO
• Keywords: Capital asset; Non-deduction of tax
• Section: 194C; 201(1); 6; 11

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH A, HYDERABAD BEFORE SMT P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA NO. 1707/HYD/2013 ASSESSMENT YEAR: 2007-08 ASST. COMMISSIONER OF INCOME- TAX, CIRCLE 15(2), HYDERABAD. VS. M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY COMPANY LTD., VISAKHAPATNAM. PAN AABCV22404 (APPELLANT) (RESPONDENT) C.O. NO. 20/HYD/2014 (IN ITA NO. 1707/HYD/2013 ASSESSMENT YEAR: 2007-08) M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY COMPANY LTD., VISAKHAPATNAM. PAN AABCV22404 VS. ASST. COMMISSIONER OF INCOME-TAX, CIRCLE 15(2), HYDERABAD. (CROSS OBJECTOR) (RESPONDENT) REVENUE BY : SHRI T. VENKAT REDDY ASSESSEE BY : SHRI S. RAMA RAO DATE OF HEARING 08-08-2016 DATE OF PRONOUNCEMENT 24-08-2016 O R D E R PER S. RIFAUR RAHMAN, A.M.: THIS APPEAL IS PREFERRED BY THE REVENUE AGAINST TH E ORDER OF THE LEARNED COMMISSIONER OF INCOME-TAX(A) - II, HYD ERABAD, DATED 02/09/2013 FOR AY 2007-08. 2 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. 2. BRIEFLY THE FACTS OF THE CASE ARE THAT THE AO NO TED THAT THE ASSESSEE DURING THE AY HAS MADE THE FOLLOWING PAYME NTS UNDER VARIOUS HEADS WITHOUT DEDUCTING TAX AT SOURCE: S. N O. NATURE OF PAYMENT AMOUNT OF PAYMENT RATE OF TAX TAX OUGHT TO HAVE BEEN DEDUCTED U/S 201(1) INTEREST CHARGEABLE U/S 201(1A) FROM 01/04/2006 TO 31/03/2011. A INTEREST PAYMENTS WHICH ATTRACT THE PROVISIONS OF SECTION 194A OF THE ACT VIDE ITEM NO. (II)(E) OF ANNEXURE TO THE AUDIT REPORT 1155.83 LAKHS 22.44% 25,93,12,825 15,55,87,680 B LEASE RENTAL PAYMENTS WHICH ATTRACT THE PROVISIONS OF SECTION 194I OF THE ACT 54.4 LAKHS 22.44% 12,20,736 7,32,420 C LEASE RENTAL PAYMENTS BY VIRTUE OF ISSUING SHARES TO APIIC WHICH ATTRACT THE PROVISIONS OF SECTION 194I OF THE ACT 15.50 CRORES 22.44% 3,47,82,000 2,08,69,200 D CONTRACT PAYMENTS (OPERATION AND MAINTENANCE CHARGES) WHICH ATTRACT THE PROVISIONS OF SECTION 194C OF THE ACT 8.37 CRORES 2.244% 18,78,228 11,26,920 E CONTRACT PAYMENTS (OPERATION AND MAINTENANCE CHARGES) WHICH ATTRACT THE PROVISIONS OF SECTION 194C OF THE ACT 9,90,000 2.244% 22,216 13,320 F PAYMENT TO SRI JAGANNADHA RAO WHICH ATTRACTS THE PROVISIONS OF SECTION 194J OF THE ACT 1,40,450 5.61% 7,879 4,680 G AUDIT FEES WHICH ATTRACTS THE PROVISIONS OF SECTION 194J 3,40,328 5.61% 19,092 11,400 TOTAL 29,72,42,976 17,83,45,620 3 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. 3. THE AO OBSERVED THAT SECTION 201(1) OF THE ACT P ROVIDES FOR CONSEQUENCES OF FAILURE TO DEDUCT TAX AT SOURCE. AS PER THE PROVISIONS OF THIS SECTION, ANY PERSON WHO FAILS TO DEDUCT TAX AT SOURCE SHALL BE DEEMED TO BE AN ASSESSEE IN DEFAULT IN RESPECT OF T HE TAX. HENCE, THE AO RAISED A DEMAND OF RS. 29,72,42,976/- U/S 201(1) OF THE ACT. SINCE THE ASSESSEE HAS FAILED TO DEDUCT THE TAX OF RS. 29,72,42,976/- THE AO COMPUTED THE CORRESPONDING INTEREST U/S 201( 1A) AT RS. 17,83,45,620/-. 4. AGGRIEVED, THE ASSESSEE PREFERRED AN APPEAL BEFO RE THE CIT(A). 5. AS REGARDS INTEREST PAYMENT OF RS. 11,55,83,000 /-, PAID TO APIIC, THE CIT(A) OBSERVED THAT NO TDS IS DEDUCTIBL E AS PER THE PROVISIONS OF SECTION 194A(3)(B) AS ANY INTEREST PA ID TO ANY FINANCIAL CORPORATION ESTABLISHED UNDER CENTRAL, STATE OR PRO VINCIAL ACT ARE EXEMPT FROM TDS. HE, THEREFORE, HELD THAT SINCE AP IIC IS A STATE GOVT. UNDERTAKING, NO TDS IS LEVIABLE ON PAYMENT TO APIIC. 5.1 AS REGARDS LEASE PREMIUM & RENTAL PAYMENTS OF R S.16.04 CRORES (15.50 CRORES OF PREMIUM + 54.40 LAKHS OF RE NT) WAS PAID TO APIIC, BEFORE THE CIT(A), THE ASSESSEE MADE THE FOL LOWING SUBMISSIONS: (A) THAT WITH THE MOTIVE OF GIVING BOOST TO INDUSTR IAL DEVELOPMENT IN VIZAG REGION, THE GOVERNMENT OF A.P. HAD CREATED SPECIAL PURPOSE VEHICLE TO PROVIDE WATER SUPPLY TO THE INDU STRIES IN VISAKHAPATNAM REGION. IN THIS PROCESS, THE GOVERNME NT OF A.P., HAD TO PROVIDE 1000 PLUS ACRES OF LAND TO THE APPEL LANT. THIS LAND WAS TO BE ACQUIRED FROM FARMERS, INDUSTRIES ETC. ET C. LOT OF ROADS, FIELDS, HOUSES WERE TO BE REMOVED AND PEACEFUL POSS ESSION WAS TO BE HANDED OVER TO THE APPELLANT. SINCE ALL THIS WORK WAS TEDIOUS, GOVERNMENT OF A.P. AUTHORIZED APIIC TO ACQ UIRE LAND FOR LAYING GODAVARI PIPELINE AND TO EXECUTE THE WORK VI DE G.O.M. NO.205 DATED 02.07.2003. (B) AS PER THE TERMS OF CONCESSION AGREEMENT, GOVER NMENT OF A.P. WAS TO ALLOT LAND ADMEASURING 1010 ACRES TO TH E APPELLANT COMPANY. IN TURN, IN CONSIDERATION OF RIGHT OVER TH E LAND, THE APPELLANT HAD TO PAY LEASE PREMIUM OF RS.15.150 CRO RES. THE 4 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. LEASE PREMIUM WAS TO BE PAID BY WAY OF ISSUE OF SHA RES BY THE APPELLANT EITHER TO GOVERNMENT OF A.P. OR TO ITS NO MINEES. IN ADDITION, THE APPELLANT WAS SUPPOSED TO MAKE LEASE RENT OF RS.54.40 LACS. THIS ALSO WAS TO BE PAID EITHER TO G OVERNMENT OF A.P. OR TO ITS NOMINEE. (C) THE GOVERNMENT OF A.P. HAD APPOINTED APIIC AS I TS NOMINEE. HENCE, THE PAYMENTS WERE MADE TO APIIC WHICH WAS AN AGENT OF THE PRINCIPAL I.E., GOVERNMENT OF A.P. IT WAS EMPHA SIZED THAT THE AGREEMENT OF THE APPELLANT WAS WITH THE GOVERNMENT OF A.P. AND NOT WITH APIIC. THE PAYMENTS WERE MADE TO THE AGENT (APIIC) ON THE DIRECTIONS OF THE PRINCIPAL (GOVERNMENT OF A.P. ) (D) ALTERNATIVELY THE APPELLANT SUBMITTED THAT THE LEASE HOLD LAND WAS SHOWN AS THE FIXED ASSET IN ITS BOOKS OF ACCOUN TS. ANY AMOUNT PAID TO ACQUIRE FIXED ASSET WAS A CAPITAL PA YMENT AND IS BEYOND THE PURVIEW OF TDS PROVISIONS. (E) IT WAS FURTHER SUBMITTED THAT THE APPELLANT COM PANY RECEIVED THE LAND AS CONSIDERATION TOWARDS ISSUE OF SHARES, THUS IT AMOUNTS TO CAPITAL CONTRIBUTION BY APIIC WHICH IS A GAIN BEYOND THE PURVIEW OF TDS. (F) THAT GOVERNMENT OF A.P. ACCORDED STATUS OF LOCA L AUTHORITY TO APIIC, HENCE, ANY PAYMENT MADE TO SUCH LOCAL AUTHOR ITY ARE NOT LIABLE TO TDS. (G) THE HON'BLE ITAT IN ITA NO. 1471/HYD/2010 FOR A .Y. 2007-08 DATED 22.11.2011 HELD THAT APIIC IS ENTITLED FOR EX EMPTION U/S. 11 OF THE I.T. ACT, 1961, THEREFORE, THE INCOME OF PAYEE IS EXEMPT UNDER INCOME-TAX ACT AND THEREFORE, THERE IS NO NEE D TO DEDUCT TDS. 5.2 AFTER CONSIDERING THE SUBMISSIONS OF THE ASSESS EE, THE CIT(A) OBSERVED THAT THE LEASE HOLD LAND ALLOTTED BY THE G OVERNMENT TO THE APPELLANT WAS SHOWN UNDER FIXED ASSETS. FURTHER, TH E APPELLANT HAD ALLOTTED 155,00,000 SHARES, EACH AT RS.10/ TOWARDS SITE LEASE PREMIUM. ACCORDINGLY, THESE AMOUNTS SPENT FOR ACQUI RING CAPITAL ASSET ARE NOT LIABLE TO TDS. MOREOVER, SINCE THE IN COME OF THE PAYEE (I.E. APIIC) IS EXEMPT U/S.11 OF I.T. ACT, 1961 AS HELD BY THE HON'BLE ITAT VIDE ORDER IN ITA NO. 1471/HYD/2010 DATED 22.1 1.2011, THERE IS NO NEED TO DEDUCT THE TDS ON PAYMENTS MADE TO SUCH EXEMPT ENTITY. ACCORDINGLY, THIS ISSUE IS ALLOWED IN FAVOUR OF THE APPELLANT. 5 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. 5.3 AS REGARDS THE CONTRACT PAYMENTS OF RS.8.37 CRO RES ( A) OPERATION & MAINTENANCE CHARGES RS. 2.97 CR., B) POWER CHARGES RS. 2.68 CR. AND C) WATER ABSTRACTION CHARGES RS. 2.72 CR.), THE CIT(A) OBSERVED THAT REGARDING THE POWER CHARGES AN D WATER ABSTRACTION CHARGES, AO REPORTED THAT SINCE THE PAY MENTS WERE MADE TO GOVERNMENT OF AP, THEY ARE EXEMPT FROM TDS PROVI SIONS. HENCE, THESE ISSUES WERE ALLOWED BY CIT(A) IN FAVOUR OF AS SESSEE. 5.4 REGARDING THE CONTRACT PAYMENTS OF RS. 9,90,00 0/- IT WAS SUBMITTED BY THE APPELLANT THAT, THIS AMOUNT REPRES ENTS THE PROVISION FOR EXPENSES WHICH WERE ESTIMATED ON ADHOC BASIS AS PAYABLE TO L&T. IT WAS FURTHER SUBMITTED THAT NO INVOICE WAS R AISED BY L&T AND THE PROVISION WAS REVERSED BACK IN F.Y. 2009-10. TH OUGH THE ASSESSING OFFICER IN HIS REMAND REPORT HELD THAT TD S IS LIABLE ON SUCH PAYMENT, THE CIT(A) HELD THAT NO NEED TO CONSIDER T HE SAME KEEPING IN VIEW THAT SUCH ENTRY WAS REVERSED IN SUBSEQUENT FINANCIAL YEAR. 5.5 REGARDING THE PAYMENTS MADE TO SRI JAGANANDA RA O OF RS.L,40,450/- AND AUDIT FEES OF RS.3,40,328/- THE A SSESSEE ADMITTED THAT TDS WAS DEDUCTED AND PAID TO GOVERNMENT ACCOUN T. THE CIT(A) HELD THAT , THE PROVISIONS OF SECTION 201(LA) ARE A PPLICABLE ON THE LATE PAYMENT, IF ANY. 6. AGGRIEVED BY THE ORDER OF THE CIT(A), THE REVENU E IS IN APPEAL BEFORE US RAISING THE FOLLOWING GROUNDS OF APPEAL: (1) THE LEARNED CIT(A) HAS ERRED IN HOLDING THAT T HERE IS NO NEED TO DEDUCT TDS ON PAYMENTS MADE TO AN EXEMPT ENTITY LIKE M/S. APIIC, IN WHOSE RESPECT ELIGIBILITY FOR EXEMPTION U /S. 11 HAS BEEN HELD BY THE HON'BLE ITAT. (2) THE LEARNED C1T(A) FAILED TO APPRECIATE THAT TH E ELIGIBILITY FOR EXEMPTION U/S. 11 IS TO BE DECIDED BY THE AD FROM Y EAR TO YEAR. 3) THE LEARNED CIT(A) FAILED TO APPRECIATE THAT M/S . APIIC IS A CORPORATION ESTABLISHED BY THE STATE GOVERNMENT OF ANDHRA PRADESH AND NOT BY THE CENTRAL GOVERNMENT SO AS TO ENJOY THE EXEMPTION AVAILABLE U/S. 196(III). 6 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. (4) THE LEARNED CIT(A) ERRED IN RULING THAT AS 'PRO VISION FOR EXPENSES' IS MADE ON ADHOC BASIS, NO TDS IS DEDUCTI BLE ON SUCH PROVISION, WHICH IS IN CONTRAVENTION TO THE PROVISI ONS OF SECTION 194(2) OF THE ACT. 7. THE LD. DR, ON THE OTHER HAND, RELIED ON THE ORD ERS OF REVENUE AUTHORITIES. 8. LD. AR RELIED ON THE FOLLOWING CASES: 1. IBM INDIA PVT. LTD., ITA NOS. 749 TO 752/BANG/2 012 AND OTHERS, ORDER DATED 14/05/2015. 2. JCIT VS. MUKUND LTD., [2007] 106 ITD 231 (MUM.) (SB) 3. DCIT VS. M/S RITHWIK SWATI JOINT VENTURE, ITA N O. 719/HYD/2010, ORDER DATED 18/02/2011. 4. PFIZER LTD. VS. ITO (TDS) (OSD), ITA NOS. 1667 & 1668/MUM/2010, ORDER DATED OCTOBER 31, 2012. 9. CONSIDERED THE SUBMISSIONS OF BOTH THE COUNSELS AND PERUSED THE MATERIAL FACTS ON RECORD AS WELL AS THE ORDERS OF REVENUE AUTHORITIES. 9.1 THE REVENUE HAS RAISED GROUND NOS. 1 & 2, OBJEC TING TO THE CIT(A)S ORDER, IN WHICH CIT(A) HAS OBSERVED THAT S INCE, APIIC IS A EXEMPT ENTITY U/S 11, RELYING ON THE DECISION OF IT AT, THERE IS NO NECESSITY OF TDS. IN OUR VIEW, THERE IS NO PROVISIO N IN THE IT ACT TO GRANT BLANKET PERMIT FOR NON-DEDUCTION OF TAX EXCEP T BY FOLLOWING PROCEDURE OF APPLYING TO THE APPROPRIATE AUTHORITY. TO GET THE EXEMPTION CERTIFICATE, THE CONCERN SEEKING EXEMPTIO N FROM THE DEDUCTEE, IT HAS TO APPLY TO THE DIT (EXEMPTION) WI TH THE REQUEST IN PROPER FORM, ONLY UPON APPROVAL FROM DIT (EXEMPTION ) IN WRITING, THE EXEMPTION IS ALLOWED NOT OTHERWISE. IN OUR CONSIDER ED VIEW, THE GROUNDS RAISED BY THE REVENUE ARE CORRECT. IN THE P RESENT CASE, THE CIT(A) HAS MADE THE PASSING COMMENT THAT APIIC IS A EXEMPT ENTITY, BUT, THE CIT(A) HAS ALLOWED THE GROUND OF ASSESSEE TREATING THE TRANSACTION AS CAPITAL IN NATURE. CIT(A) HAS NOT AD JUDICATED THIS 7 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. GROUND MAINLY ON EXEMPTION OF ENTITY. HENCE, THE GR OUND RAISED BY THE REVENUE IS DISMISSED. 9.2 WITH REGARD TO GROUND NO. 3, APIIC IS A CORPORA TION ESTABLISHED BY STATE GOVT. OF AP AND NOT BY CENTRAL GOVT., TO E NJOY EXEMPTION U/S 196(III). THERE IS NO DISPUTE THAT APIIC ESTABLISHE D UNDER STATE ACT. IN THE PRESENT CASE, CIT(A) HAS ALLOWED THE EXEMPTION BY TREATING THE APIIC AS A CONCERN U/S 194A(III)(B) OF THE ACT. ON CAREFUL OBSERVATION, THE CONCERN WHICH IS EXEMPT U/S 194A(III)(B) SHOULD BE A FINANCIAL CORPORATION ESTABLISHED BY OR UNDER CENTRAL, STATE OR PROVINCIAL ACT. ON THE RECORD SUBMITTED BEFORE US DOES NOT CLARIFY THAT APIIC IS A FINANCIAL CORPORATION. SINCE WE ARE NOT SURE ABOUT THE TYPE OF FINANCIAL CORPORATION, WE REMIT THIS ISSUE BACK TO THE FILE OF THE AO TO DETERMINE THE STATUS. IN CASE IT IS FOUND THAT IT I S A FINANCIAL CORPORATION, THE EXEMPTION MAY BE GRANTED. 9.3 WITH REGARD TO GROUND NO. 4, PROVISION FOR EXPE NSES IS MADE ON ADHOC BASIS, CIT(A) HAS ALLOWED AS NO TDS IS DEDUCT IBLE ON SUCH PROVISION, WHICH IS IN CONTRAVENTION TO THE PROVISI ONS OF SECTION 194(2) OF THE AC. WE ARE SURPRISED TO OBSERVE THAT THERE I S NO SUCH SECTION 194(2) IN THE ACT. THE SECTION REFERRED BY THE REVE NUE IS RELATING TDS ON DIVIDEND. SINCE, THERE IS NO RELEVANCE TO THE PR ESENT CASE, WE ARE NOT CONSIDERING THIS GROUND FOR ADJUDICATION. 10. IN THE RESULT, APPEAL OF THE REVENUE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. C.O. NO. 20/HYD/2014 BY THE ASSESSEE 11. THE ASSESSEE HAS RAISED THE FOLLOWING CROSS OBJ ECTIONS: 1. THE LEARNED COMMISSIONER OF INCOME-TAX (APPEALS ) OUGHT TO HAVE CONSIDERED THE FACT THAT THE PAYMENTS MADE BY THE APPELLANT ARE THE PAYMENTS MADE TO THE GOVERNMENT O F ANDHRA PRADESH IN ACCORDANCE WITH THE AGREEMENT ENTERED IN TO BETWEEN THE APPELLANT HEREIN AND THE GOVERNMENT OF ANDHRA P RADESH EXECUTED ON 12-03-2004 AND NO DEDUCTION OF TAX NEED TO BE MADE. 8 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. 2. THE LEARNED COMMISSIONER OF INCOME-TAX (APPEALS) OUGHT TO HAVE SEEN THAT THE APILC WAS APPOINTED AS AGENT BY THE GOVERNMENT OF ANDHRA PRADESH VIDE ITS G.O.NO.131DAT ED 26-05- 1997 AND, THEREFORE, THE PAYMENTS WERE MADE TO THE APILC AND THE APILC WAS RECEIVING THE AMOUNT AS AGENT OF GOVE RNMENT OF ANDHRA PRADESH. 3. THE LEARNED COMMISSIONER OF INCOME-TAX (APPEALS) OUGHT TO HAVE SEEN THAT APILC IS NOT THE BENEFICIARY OF THE AMOUNT PAID BY THE APPELLANT HEREIN AND THE BENEFICIARY IS THE GOV ERNMENT OF ANDHRA PRADESH AND, THEREFORE, TO HAVE HELD THAT NO TAX NEED BE DEDUCTION AT SOURCE EITHER FROM THE PAYMENT OF INTE REST OR THE PAYMENT OF LEASE RENTALS OR THE PREMIUM TOWARDS THE LAND LEASE. 12. SINCE THE GROUNDS RAISED BY THE REVENUE ARE DIS MISSED, THE CROSS OBJECTIONS RAISED BY ASSESSEE BECOME INFRUCTU OUS, THEREFORE, THE SAME ARE DISMISSED AS INFRUCTUOUS. 13. IN THE RESULT, APPEAL OF THE REVENUE IS PARTLY ALLOWED FOR STATISTICAL PURPOSES AND THE C.O. BY THE ASSESSEE I S DISMISSED. PRONOUNCED IN THE OPEN COURT ON 24 TH AUGUST, 2016. SD/- SD/- (P. MADHAVI DEVI) (S. RIFAUR RAH MAN) JUDICIAL MEMBER A CCOUNTANT MEMBER HYDERABAD, DATED: 24 TH AUGUST, 2016 KV COPY TO:- 1) ACIT, CIRCLE 15(2), ROOM NO. 444, 4 THH FLOOR, D BLOCK, IT TOWERS, AC GUARDS, HYDERABAD. 2) M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. L TD., C/O GREATER VISAKHAPATNAM MUNICIPAL CORPORATION , ROOM NO. 24, TENNETI BHAVAN, ASLIMETTA JUNCTION, VISAKHAPATNA M. 3) CIT(A) - II, HYDERABAD 4) CIT(TDS), HYDERABAD 5) THE DEPARTMENTAL REPRESENTATIVE, I.T.A.T., HYDE RABAD. 9 ITA NO. 1707/H/13 & CO. 20/HYD/2014 M/S VISAKHAPATNAM INDUSTRIAL WATER SUPPLY CO. LTD. S.NO. DESCRIPTION DATE INTLS 1. DRAFT DICTATED ON SR.P.S./P.S 2. DRAFT PLACED BEFORE AUTHOR SR.P.S/PS 3 DRAFT PROPOSED & PLACED BEFORE THE SECOND MEMBER JM/AM 4 DRAFT DISCUSSED/APPROVED BY SECOND MEMBER JM/AM 5 APPROVED DRAFT COMES TO THE SR.P.S./PS SR.P.S./ P.S 6. KEPT FOR PRONOUNCEMENT ON SR. P.S./P.S. 7. FILE SENT TO THE BENCH CLERK SR.P.S./P.S 8 DATE ON WHICH FILE GOES TO THE HEAD CLERK 9 DATE OF DISPATCH OF ORDER