M/s. Ashishkumar Ankitkumar & Co., Ahmedabad V. The ACIT.,Cent.,Circle-2(2), Ahmedabad

ITA 1708/AHD/2011

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 6152 (ITAT-AHMEDABAD)
• Duration Of Justice: 8 year(s) 7 month(s) 16 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-02-2020
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Next Hearing Date: 23-01-2020
• Assessment Year: 2009-2010
• Appeal Filed On: 27-06-2011
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: DEELIPKUMAR
• Keywords: Document seized; Documents seized
• Section: 143(3); 133A; 153A; 274; 207; 13; 132; 139

Judgement Text

, IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH, AHMEDABAD BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI WASEEM AHMED, ACCOUNTANT MEMBER ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASSESSMENT YEAR : 2009-10 M/S. ASHISHKUMAR ANKITKUMAR & CO., 2948, AMBLI POLE, ZAVERIWAD, RATANPOLE, AHMEDABAD-380001 [PAN: AAPFA 6975 R] VS ASSTT. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 2(2), AHMEDABAD / (APPELLANT) / (RESPONDENT) ASSESSEE BY : SHRI TUSHAR HEMANI, AR REVENUE BY : SHRI DEELIP KUMAR, SR DR / DATE OF HEARING : 23/01/2020 / DATE OF PRONOUNCEMENT: 13/02/2020 / O R D E R PER RAJPAL YADAV, VICE PRESIDENT :- THE PRESENT TWO APPEALS ARE DIRECTED AT THE INSTANC E OF THE ASSESSEE AGAINST TWO SEPARATE ORDERS OF THE LEARNED CIT(A)-I II, AHMEDABAD DATED 18.04.2011 AND 18.02.2013 PASSED FOR ASSESSMENT YEA R 2009-10. ITA NO.1708/AHD/2011 EMERGES OUT OF PROCEEDINGS UNDER S ECTION 143(3) OF THE INCOME-TAX ACT, 1961 (HEREINAFTER REFERRED TO AS T HE ACT); WHEREAS ITA NO.1169/AHD/2013 AROSE AGAINST PENALTY IMPOSED UNDE R SECTION 271AAA OF THE ACT. 2. FIRST, WE TAKE UP ITA NO. 1708/AHD/2011. THE GRO UNDS OF APPEAL TAKEN BY THE ASSESSEE ARE NOT IN CONSONANCE WITH RU LE 8 OF INCOME TAX (APPELLATE TRIBUNAL) RULES, 1963; THEY ARE DESCRIPT IVE AND ARGUMENTATIVE IN NATURE. IN BRIEF, THE GRIEVANCE OF THE ASSESSEE IS THAT LEARNED CIT(A) HAS ERRED IN CONFIRMING THE ADDITION OF RS.18,20,407/-. ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASHISHKUMAR ANKITKUMAR & CO VS. ACIT AY : 2009-10 2 3. THE BRIEF FACTS OF THE CASE ARE THAT A SURVEY UN DER SECTION 133A OF THE INCOME-TAX ACT WAS CARRIED OUT AT THE BUSINESS PREM ISES OF M/S. ASHISH KUMAR ANKIT KUMAR & CO., SITUATED AT 1 ST FLOOR, 311, KUCHA GHASI RAM, FATEH PURI, CHANDANI CHOWK, DELHI. DURING THE COUR SE OF SURVEY, A SUM OF RS.27.57 LAKHS WAS RECOVERED FROM THE BUSINESS PREM ISES. AS THE ASSESSEE WAS UNABLE TO EXPLAIN THE CASH FOUND/RECOVERED; THE REFORE, THE SURVEY WAS CONVERTED INTO SEARCH UNDER SECTION 132(1) OF THE A CT. IT EMERGES OUT FROM THE RECORD THAT INITIALLY THE ASSESSEE TOOK THE STA ND THAT THIS SUM OF RS.27.57 LAKHS WAS OF SOME CLIENTS WHO HAVE GIVEN TO THE ASS ESSEE FOR ANGADIYA SERVICES. LATER ON, THE ASSESSEE CHANGED THE STAND AND OFFERED IT AS A COMMISSION INCOME. THE ASSESSING OFFICER, APART FR OM THIS, FURTHER ESTIMATED COMMISSION INCOME OF RS.25 LAKHS AND DETE RMINED THE TAXABLE INCOME OF THE ASSESSEE AT RS.53,89,840/-. 4. ON APPEAL, LEARNED CIT(A) PARTLY UPHELD THE ORDE R OF THE ASSESSING OFFICER. THE FINDINGS OF THE LEARNED CIT(A) READ A S UNDER:- 5. I DO NOT AGREE FULLY WITH THE AR OF THE APPELLA NT. FOR THE PURPOSE OF WORKING OUT THE DAILY TURNOVER, MONTHLY TURNOVER OR THE TURNOVER FOR 207 DAYS AS SHOWN IN THE ABOVE MENTIONED TABLE, THE APP ELLANT HAS INCLUDED THE SEIZED CASH IS AMOUNT OF RS. 27.50 LACS AS THE COMM ISSION INCOME. THIS IS NOT CORRECT. WHEN THE PARTNER OF THE APPELLANT WAS ASKED TO STATE AS TO WHICH PARTY THE CASH OF RS. 27.50 LACS BELONGED TO, HE CO ULD NOT STATE THEIR NAMES. EVEN SUBSEQUENTLY THE NAME OF THE CONCERNED PARTIES WAS NOT GIVEN BY THE APPELLANT AS IT WOULD HAVE ADVERSELY AFFECTED THE B USINESS OF THE APPELLANT. THEREFORE, THE APPELLANT OWNED UP THE CASH BELONGIN G TO ITS CLIENTS AND AGREED TO PAY THE TAXES THEREON IN ORDER TO BUY THE PEACE OF MIND. THE AMOUNT OF RS.27.50 LACS CANNOT BE THEREFORE TREATED AS THE COMMISSION INCOME OF THE APPELLANT. IF THIS AMOUNT IS EXCLUDED , THEN THE TURNOVER OF THE APPELLANT ON THE BASIS OF THE SEIZED DOCUMENTS CAN BE WORKED OUT AS UNDER: IT MAY BE MENTIONED THAT DURING THE COURSE OF SEARC H SOME DOCUMENTS WERE FOUND WHICH INDICATED THE TOTAL TURNOVER OF TH E APPELLANT FOR THREE DATES NAMELY ON 2/12/2008 TOTAL TURNOVER OF RS. 20,69,950 /-, ON 3/12/2008 TOTAL TURNOVER RS. 61,56,350/- AND ON 4/12/2008 TOTAL TUR NOVER OF RS. 43,35,460/-. IN OTHER WORDS, THE AVERAGE TURNOVER FOR THE THREE DAYS WAS RS.41,87,253/-. IF ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASHISHKUMAR ANKITKUMAR & CO VS. ACIT AY : 2009-10 3 THIS FIGURE IS TAKEN AS THE AVERAGE TURNOVER FOR 2 07 DAYS, THEN THE TOTAL TURNOVER DURING THIS PERIOD COMES TO RS.86,67,61,44 0/-. IF THE RATE OF COMMISSION IS TAKEN AT RUPEES 200 PER LAKH THEN THE COMMISSION INCOME OF THE APPELLANT FOR 207 DAYS COMES TO RS. 17,33,522/- AND IF THE COMMISSION INCOME OF RS.300 PER LAKH IS CONSIDERED, THEN THE T OTAL COMMISSION INCOME OF THE APPELLANT COMES TO RS. 26,00,284/-. IT MAY BE M ENTIONED THAT ONE OF THE PARTNER OF THE APPELLANT HAD ADMITTED THE COMMISSIO N INCOME OF RS. 25 LACS IN THE STATEMENT RECORDED AFTER THE DATE OF SEARCH. IN OTHER WORDS, THE APPELLANT WAS CHARGING COMMISSION BETWEEN RS. 200 T O RS. 300 PER LAKH. IN OTHER WORDS, THE STATEMENT GIVEN BY THE PARTNER OF THE APPELLANT WAS BASED ON THE ACTUAL COMMISSION INCOME EARNED BY THE APPELLAN T UPTO THAT DATE AND THEREFORE, THERE WERE NO VALID REASON FOR RETRACTIN G THIS STATEMENT BY THE PARTNERS. IN OTHER WORDS, THE APPELLANT HAS EARNED GROSS COMMISSION INCOME OF RS. 25 LACS DURING 207 DAYS AS MENTIONED ABOVE. 5.1 IN THE PROFIT AND LOSS ACCOUNT, THE APPELLANT H AS DEBITED TOTAL EXPENDITURES OF RS. 6,79,593/-. THEREFORE, THE ADDI TION OF RS. 25 LACS MINUS RS. 6,79,593/- = RS. 18,20,407/- IS UPHELD AS THE N ET COMMISSION INCOME OF THE APPELLANT INSTEAD OF RS. 25 LACS CONSIDERED BY THE AO. 5. LEARNED COUNSEL FOR THE ASSESSEE, AT THE VERY OU TSET, CONTENDED THAT THOUGH RS. 27.50 LAKHS WAS NOT INITIALLY ADMITTED B Y THE ASSESSEE AS COMMISSION INCOME; BUT LATER ON IT WAS CONSIDERED A S A COMMISSION INCOME AND OFFERED FOR TAXATION. THERE IS NO JUSTIFIABLE REASON AT THE END OF THE LEARNED CIT(A) TO EXCLUDE THIS AMOUNT FROM THE TOTA L INCOME OF THE ASSESSEE REPRESENTING COMMISSION INCOME. THE LEARNED CIT(A) HAS DETERMINED RS.25 LAKHS AS ESTIMATED COMMISSION INCOME; THEREAFTER DE BITED THE EXPENDITURE AND CONFIRMED ADDITION OF RS.18,20,407/-, BUT SET O FF OF RS.27.50 LAKHS DISCLOSED BY THE ASSESSEE HAS NOT BEEN GIVEN. ON T HE OTHER HAND, LEARNED DEPARTMENTAL REPRESENTATIVE CONTENDED THAT THE AMOU NT OF RS.27.50 LAKHS IS A SEPARATE AMOUNT AND IT CANNOT BE TREATED AS COMMI SSION INCOME. 6. WE HAVE DULY CONSIDERED THE RIVAL CONTENTIONS AN D GONE THROUGH THE RECORD CAREFULLY. A PERUSAL OF THE ORDER OF LEARNE D CIT(A) WOULD INDICATE THAT LEARNED FIRST APPELLATE AUTHORITY HAS ESTIMATE D THE COMMISSION INCOME OF THE ASSESSEE FOR 207 DAYS. THE WORKING O F 207 DAYS HAS BEEN ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASHISHKUMAR ANKITKUMAR & CO VS. ACIT AY : 2009-10 4 TAKEN BY THE LEARNED CIT(A) FROM THE DAY WHEN THE A SSESSEE-FIRM CAME INTO EXISTENCE BY EXECUTION OF THE PARTNERSHIP DEED. I T CAME INTO EXISTENCE ON 7 TH MAY 2008 AND ENDED ON 4 TH DECEMBER 2008. THE AVERAGE TURNOVER WHICH HAS BEEN WORKED OUT BY THE LEARNED CIT(A) IS BASED ON THE TURNOVER OF THREE DAYS, I.E. IMMEDIATELY PRIOR TO THE SURVEY. TO OUR MIND, THE COMMISSION INCOME OF THE ASSESSEE WAS TO BE ESTIMATED FOR THE PERIOD DURING WHICH THE FIRM REMAINED IN EXISTENCE FOR THE RELEVANT ACCOUNT ING YEAR, I.E. FOR THE NUMBER OF DAYS RELATING TO ASSESSMENT YEAR 2009-10 IT REMAINED INTO EXISTENCE. ITS EXISTENCE HAS BEEN WORKED OUT FOR 2 07 DAYS. ONCE, AFTER TAKING INTO CONSIDERATION THE TURNOVER, THE COMMISSION INC OME HAS BEEN WORKED OUT AT A SUM OF RS.25 LAKHS, THEN HOW THE COMMISSIO N INCOME ALREADY ACCOUNTED FOR BY THE FIRM AT RS.27.50 LAKHS COULD N OT BE SET OFF. WE COULD APPRECIATE THE CASE OF THE REVENUE, IF AFTER TAKING INTO THE AVERAGE COMMISSION INCOME FOR THREE DAYS, THE LEARNED CIT(A ) WORKED OUT THE COMMISSION INCOME OF 207 DAYS AT RS.27.50 LAKHS PLU S RS.25 LAKHS. IN THAT SITUATION, THE STAND OF THE REVENUE NOT TO GIVE SET OFF OF RS.27.50 LAKHS COULD BE JUSTIFIED. BUT IN THE PRESENT SITUATION, THE ONL Y METHOD WHICH COULD BE ADOPTED IS TO WORK OUT TOTAL COMMISSION INCOME FOR 207 DAYS BY WHATEVER METHOD, THEN DEBIT THAT COMMISSION INCOME FROM THE AMOUNT ALREADY DISCLOSED BY THE ASSESSEE PLUS EXPENDITURE AND THE REMAINING WILL BE TAXABLE. THE DISCLOSURE MADE BY THE ASSESSEE AT RS .27.50 LAKHS IS MORE THE ULTIMATE ESTIMATED INCOME WORKED OUT BY THE LEA RNED CIT(A); THEREFORE, NO FURTHER ADDITION IS REQUIRED. ACCORDINGLY, THE ADDITION OF RS.18,20,407/- IS DELETED AND THE APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. 7. NOW WE TAKE UP ITA NO. 1169/AHD/2013. THIS APP EAL OF THE ASSESSEE IS DIRECTED AGAINST THE ORDER OF THE LEARN ED CIT(A)-III, AHMEDABAD DATED 18.02.2013 FOR ASSESSMENT YEAR 2009-10. ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASHISHKUMAR ANKITKUMAR & CO VS. ACIT AY : 2009-10 5 8. THE SOLITARY GRIEVANCE OF THE ASSESSEE IS THAT L EARNED CIT(A) HAS ERRED IN CONFIRMING THE PENALTY OF RS.4,57,041/- WHICH WA S IMPOSED BY THE ASSESSING OFFICER UNDER SECTION 271AAA(2)(II) OF TH E ACT. 9. THE PENALTY UNDER SECTION 271AAA(2)(II) HAS BEEN IMPOSED QUA THE ADDITION OF RS.27,50,000/- AND RS.18,20,407/-. IN OTHER WORDS, THE TOTAL AMOUNT CONSIDERED FOR COMPUTING THE PENALTY IS RS.4 5,70,407/- AND 10% OF THIS AMOUNT HAS BEEN CALCULATED AS PENALTY IMPOSABL E UPON THE ASSESSEE UNDER SECTION 271AAA OF THE ACT. IN THIS WAY, LEA RNED ASSESSING OFFICER HAS IMPOSED THE PENALTY OF RS.4,57,041/-. APPEAL T O THE LEARNED CIT(A) DID NOT BRING ANY RELIEF TO THE ASSESSEE. 10. WITH THE ASSISTANCE OF THE LEARNED REPRESENTATI VES, WE HAVE GONE THROUGH THE RECORD CAREFULLY. SECTION 271AAA HAS A DIRECT BEARING ON THE CONTROVERSY; THEREFORE, IT IS PERTINENT TO TAKE NOT E OF THIS SECTION WHICH READS AS UNDER:- 271AAA. (1) THE ASSESSING OFFICER MAY, NOTWITHSTANDING ANYT HING CONTAINED IN ANY OTHER PROVISIONS OF THIS ACT, DIRE CT THAT, IN A CASE WHERE SEARCH HAS BEEN INITIATED UNDER SECTION 132 ON OR A FTER THE 1ST DAY OF JUNE, 2007 BUT BEFORE THE 1ST DAY OF JULY, 2012, THE ASSE SSEE SHALL PAY BY WAY OF PENALTY, IN ADDITION TO TAX, IF ANY, PAYABLE BY HIM , A SUM COMPUTED AT THE RATE OF TEN PER CENT OF THE UNDISCLOSED INCOME OF T HE SPECIFIED PREVIOUS YEAR. (2) NOTHING CONTAINED IN SUB-SECTION (1) SHALL APPL Y IF THE ASSESSEE, (I) IN THE COURSE OF THE SEARCH, IN A STATEMENT U NDER SUB-SECTION (4) OF SECTION 132, ADMITS THE UNDISCLOSED INCOME AND S PECIFIES THE MANNER IN WHICH SUCH INCOME HAS BEEN DERIVED; (II) SUBSTANTIATES THE MANNER IN WHICH THE UNDISCL OSED INCOME WAS DERIVED; AND (III) PAYS THE TAX, TOGETHER WITH INTEREST, IF ANY, IN RESPECT OF THE UNDISCLOSED INCOME. (3) NO PENALTY UNDER THE PROVISIONS OF CLAUSE (C) O F SUB-SECTION (1) OF SECTION 271 SHALL BE IMPOSED UPON THE ASSESSEE IN RESPECT O F THE UNDISCLOSED INCOME REFERRED TO IN SUB-SECTION (1). ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASHISHKUMAR ANKITKUMAR & CO VS. ACIT AY : 2009-10 6 (4) THE PROVISIONS OF SECTIONS 274 AND 275 SHALL, S O FAR AS MAY BE, APPLY IN RELATION TO THE PENALTY REFERRED TO IN THIS SECTION . EXPLANATION.FOR THE PURPOSES OF THIS SECTION, (A) 'UNDISCLOSED INCOME' MEANS (I) ANY INCOME OF THE SPECIFIED PREVIOUS YEAR RE PRESENTED, EITHER WHOLLY OR PARTLY, BY ANY MONEY, BULLION, JEWELLERY OR OTHER V ALUABLE ARTICLE OR THING OR ANY ENTRY IN THE BOOKS OF ACCOUNT OR OTHER DOCUMENT S OR TRANSACTIONS FOUND IN THE COURSE OF A SEARCH UNDER SECTION 132, WHICH HAS (A) NOT BEEN RECORDED ON OR BEFORE THE DATE OF SEAR CH IN THE BOOKS OF ACCOUNT OR OTHER DOCUMENTS MAINTAINED IN THE NORMAL COURSE RELATING TO SUCH PREVIOUS YEAR; OR (B) OTHERWISE NOT BEEN DISCLOSED TO THE PRINCIPAL C HIEF COMMISSIONER OR CHIEF COMMISSIONER OR PRINCIPAL COMMISSIONER OR COM MISSIONER BEFORE THE DATE OF SEARCH; OR (II) ANY INCOME OF THE SPECIFIED PREVIOUS YEAR RE PRESENTED, EITHER WHOLLY OR PARTLY, BY ANY ENTRY IN RESPECT OF AN EXPENSE RECOR DED IN THE BOOKS OF ACCOUNT OR OTHER DOCUMENTS MAINTAINED IN THE NORMAL COURSE RELATING TO THE SPECIFIED PREVIOUS YEAR WHICH IS FOUND TO BE FALSE AND WOULD NOT HAVE BEEN FOUND TO BE SO HAD THE SEARCH NOT BEEN CONDUCTED; (B) 'SPECIFIED PREVIOUS YEAR' MEANS THE PREVIOUS Y EAR (I) WHICH HAS ENDED BEFORE THE DATE OF SEARCH, B UT THE DATE OF FILING THE RETURN OF INCOME UNDER SUB-SECTION (1) OF SECTION 1 39 FOR SUCH YEAR HAS NOT EXPIRED BEFORE THE DATE OF SEARCH AND THE ASSESSEE HAS NOT FURNISHED THE RETURN OF INCOME FOR THE PREVIOUS YEAR BEFORE THE SAID DAT E; OR (II) IN WHICH SEARCH WAS CONDUCTED . 11. A PERUSAL OF SUB-SECTION (2) OF SECTION 271AAA WOULD INDICATE THAT AN ASSESSEE COULD BE ABSOLVED FROM THE LEVY OF PENALTY IF THE CONDITIONS ENUMERATED IN SUB-SECTION (2) ARE BEING FULFILLED B Y THE ASSESSEE. THE CONDITIONS ENUMERATED IN SUB-SECTION (2) ARE THAT P ENALTY UNDER SECTION 271AAA WOULD NOT BE LEVIABLE UPON ASSESSEE IF THE A SSESSEE, DURING THE COURSE OF SEARCH, HAS ADMITTED THE UNDISCLOSED INCO ME; SPECIFIED THE MANNER IN WHICH SUCH INCOME HAS BEEN DERIVED; SUBST ANTIATED THE MANNER IN WHICH THE UNDISCLOSED INCOME WAS DERIVED AND PAI D THE TAXES TOGETHER WITH INTEREST, IF ANY, IN RESPECT OF THE UNDISCLOSE D INCOME. AS SUBMITTED BY THE ASSESSEE, IT HAS NOT FIRSTLY ADMITTED THE CASH RECOVERED DURING THE COURSE ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASHISHKUMAR ANKITKUMAR & CO VS. ACIT AY : 2009-10 7 OF SEARCH AT RS.27.50 LAKHS. THEREFORE, IT DOES NO T FULFILL THE CONDITIONS ENUMERATED IN SUB-SECTION (2) OF SECTION 271AAA OF THE ACT. EVEN COPY OF THE STATEMENT RECORDED UNDER SECTION 132(4) HAS NOT BEEN PLACED BEFORE US. THEREFORE, AFTER GOING THROUGH THE RECORD, WE ARE O F THE VIEW THAT THE ASSESSEE FAILED TO FULFILL THE CONDITIONS OF SECTIO N 271AAA. IT, THEREFORE, DESERVES TO BE VISITED WITH PENALTY. HOWEVER, THE PENALTY IS TO BE RESTRICTED QUA 10% OF THE ADDITIONS WE HAVE CONFIRMED. IN OTHER WORDS, THE PENALTY WAS CALCULATED ON THE FOLLOWING AMOUNTS:- 1. UNDISCLOSED INCOME OFFERED FOR TAX IN RETURN OF INCOME FILED IN RESPECT TO NOTICE U/S 153A RS.27,50,000 2. UNDISCLOSED COMMISSION INCOME AS CONFIRMED BY CIT(A) VIDE NO.CIT(A)-III/258 /ACIT-CC-2(2)/10-11 DTD 18/04/2011 RS.18,20,407 UNDISCLOSED INCOME WITHIN THE MEANING OF EXPLANATION (A) TO SECTION 271AAA RS.45,70,407 WE HAVE ALREADY DELETED RS.18,20,407/-; THEREFORE, 10% OF THIS IS TO BE EXCLUDED. THE PENALTY IS, THEREFORE, RESTRICTED TO RS.2,75,000/-, INSTEAD OF RS.4,57,041/- IMPOSED BY THE ASSESSING OFFICER. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. 12. IN THE RESULT, BOTH THE APPEALS OF THE ASSESSEE ARE PARTLY ALLOWED. ORDER PRONOUNCED IN THE COURT ON 13 TH FEBRUARY 2020 AT AHMEDABAD. SD/- SD/- ( WASEEM AHMED ) (RAJPAL YADAV) ACCOUNTANT MEMBER VICE PRESIDENT AHMEDABAD, DATED 13/02/2020 *BT ITA NOS. 1708/AHD/2011 & 1169/AHD/2013 ASHISHKUMAR ANKITKUMAR & CO VS. ACIT AY : 2009-10 8 / COPY OF THE ORDER FORWARDED TO : 1. ! / THE APPELLANT 2. '! / THE RESPONDENT. 3. & ( / CONCERNED CIT 4. ( ) ( / THE CIT(A)- 5. & , & , /DR,ITAT, AHMEDABAD, 6. 1 / GUARD FILE. / BY ORDER, TRUE COPY (ASSTT. REGISTRAR) & ITAT, AHMEDABAD 1. DATE OF DICTATION- 12.02.2020 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 12.02.2020 OTHER MEMBER 13.02.2020. 3. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR.P. S./P.S. - 13.02.2020 4. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE D ICTATING MEMBER FOR PRONOUNCEMENT ..13.02.2020. 5. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK13.02.2020 6. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK . 7. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT REG ISTRAR FOR SIGNATURE ON THE ORDER 8. DATE OF DESPATCH OF THE ORDER