The Dy. Commissioner of Income Tax (Exemptions), Circle-1, Ahmedabad V. Mudra Foundation for Communication Research & Education, Ahmedabad

ITA 1910/AHD/2016

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 8420 (ITAT-AHMEDABAD)
• Duration Of Justice: 1 year(s) 8 month(s) 30 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-04-2018
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: Not Allotted
• Assessment Year: 2012-2013
• Appeal Filed On: 19-07-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Depreciation; Charitable institution; Capital expenditure
• Section: 143(3); 12A; 11

Judgement Text

ITA NO. 1910/AHD/2016 DCIT VS. MUDRA FOUNDATION FOR COMM. RESEARCH & EDN ASSESSMENT YEAR: 2012-13 PAGE 1 OF 5 IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD A BENCH, AHMEDABAD [CORAM: PRAMOD KUMAR AM AND RAJPAL YADAV JM] ITA NO. 1910/AHD/2016 ASSESSMENT YEAR: 2012-13 DEPUTY COMMISSIONER OF INCOME-TAX ............ ......APPELLANT (EXEMPTIONS), CIRCLE-1, AHMEDABAD VS. MUDRA FOUNDATION FOR COMMUNICATION ...........................RESPONDENT RESEARCH & EDUCATION, NR. DOCTOR HOUSE, PARIMAL CROSSING, ELLISBRIDGE, AHMEDABAD [PAN : AAATM 2168 D] APPEARANCES BY: SAURABH SINGH FOR THE APPELLANT Y G SHAH FOR THE RESPONDENT DATE OF CONCLUDING THE HEARING : 13.03.2018 DATE OF PRONOUNCING THE ORDER : 18.04.2018 O R D E R PER PRAMOD KUMAR, AM: 1. THIS APPEAL, FILED BY THE ASSESSING OFFICER, IS DIRECTED AGAINST THE ORDER DATED 24 TH MAY, 2016 PASSED BY THE CIT(A)-9, AHMEDABAD, IN TH E MATTER OF ASSESSMENT UNDER SECTION 143(3) OF THE INCOME-TAX ACT, 1961, FOR THE ASSESSMENT YEAR 2012-13. 2. THE GRIEVANCES RAISED BY THE ASSESSING OFFICER ARE AS FOLLOWS:- 1. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES O F THE CASE THE LD. CIT(A) IS JUSTIFIED IN ALLOWING THE ASSESSEES APPEAL NEGLECT ING THE FINDING OF ASSESSING OFFICER REGARDING ADDITION OF RS.3,12,63,102/- AND RS.2,00,00,000/- BEING ACCUMULATION CLAIMED U/S 11(1)(A) AND 11(2) OF THE ACT RESPECTIVELY. 2. WHETHER ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE THE LD. CIT(A) IS JUSTIFIED IN ALLOWING THE ASSESSEES APPEAL NEGLECT ING THE FINDING OF ASSESSING OFFICER REGARDING ADDITION OF RS.70,75,586/- BEING CAPITAL EXPENDITURE CLAIMED U/S 11 OF THE ACT. 3. LEARNED REPRESENTATIVES FAIRLY AGREE THAT THE AF ORESAID ISSUES ARE COVERED, IN FAVOUR OF THE ASSESSEE, BY THE ORDER DATED 07.07.20 17 PASSED BY THE COORDINATE BENCH IN ITA NO.1644/AHD/2014, IN ASSESSEES OWN CA SE FOR THE ASSESSMENT YEAR 2009-10, WHEREIN THE TRIBUNAL HAS HELD AS UNDER:- ITA NO. 1910/AHD/2016 DCIT VS. MUDRA FOUNDATION FOR COMM. RESEARCH & EDN ASSESSMENT YEAR: 2012-13 PAGE 2 OF 5 9. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE RECORDS PLACED BEFORE US AND GONE THROUGH THE JUDGMENT OF HONBLE APEX CO URT AND JURISDICTIONAL HIGH COURT IN THE CASE OF ASSESSEE. REVENUE HAS RAISED T HE ISSUE ABOUT THE NATURE OF ACTIVITIES CARRIED ON BY THE ASSESSEE AS TO WHETHER THEY ARE IN THE NATURE OF EDUCATIONAL ACTIVITIES U/S.2(15) OF THE ACT OR IN T HE NATURE OF TRADE OR COMMERCE PROVIDED IN PROVISO TO SECTION 2(15) OF THE ACT. W E OBSERVE THAT ASSESSEE IS A CHARITABLE TRUST REGISTERED U/S.12AA OF THE ACT. IT S MAIN BUSINESS IS TO PREPARE VARIOUS PERSON FOR CARRIER IN THE FIELD OF COMMUNIC ATION AND ADVERTISING. IT PROVIDE 2 YEAR PGDM COURSE AND IS REGISTERED WITH ALL INDIA COUNCIL OF TECHNICAL EDUCATION (AICTE). IT ALSO ADMINISTERS SHORT TERM C OURSES CALLED CAREER DEVELOPMENT AND PROFESSIONAL DEVELOPMENT. 10. WE OBSERVE THAT LD.CIT(A) HAS ALLOWED ASSESSEE S PLEA AND ACCEPTED IT AS TRUST CARRYING ON CHARITABLE ACTIVITIES BY WAY OF P ROVIDING EDUCATION BY OBSERVING AS FOLLOWS: 5.3 I HAVE CONSIDERED THE ASSESSMENT ORDER AND THE SUBMISSIONS MADE BY THE APPELLANT. THE APPELLANT IS A CHARITABLE TRUST REGISTERED UNDER SECTION 12A OF THE ACT, WHICH IS ENGAGED IN ADMINISTERING M UDRA INSTITUTE OF COMMUNICATIONS (MICA). MICA IS ENGAGED IN PROVIDING HIGHER EDUCATION IN THE FIELD OF COMMUNICATIONS AND ADVERTISING. MIC A PROVIDES TRAINING TO STUDENTS IN THE FIELD OF COMMUNICATIONS AND ADVERTI SING AND CONDUCTS FLAGSHIP 2 YEAR COURSE CALLED PGDM WHICH IS APPROVE D BY THE AICTE. THE COURSE IS CONSIDERED TO BE ONE OF THE BEST MANAGEME NT COURSES IN COMMUNICATIONS AND ADVERTISING IN INDIA. APART FROM THAT, THERE ARE OTHER SHORT-TERM COURSES FOR QUALIFIED PROFESSIONALS AND MID-TERM PRACTITIONERS. THE COURSES BEING CONDUCTED BY MICA ARE IN NATURE O F SYSTEMATIC INSTRUCTION WITH DEFINED COURSE CONTENTS, CLASSROOM TRAINING, ETC. THE APPELLANT IS PRIMARILY EXISTING FOR THE PURPOSE OF PROVIDING EDUCATION AND TRAINING IN THE FIELD OF COMMUNICATION AND ADVERTIS ING. 5.4 I THEREFORE DO NOT AGREE WITH THE OBSERVATION O F THE ASSESSING OFFICER THAT THE ACTIVITIES OF THE ASSESSEE IS NOT EDUCATION BUT ANY OTHER ACTIVITY OF GENERAL PUBLIC INTEREST. THE WORD 'EDUC ATION' HAS TO BE GIVEN ITS NATURAL MEANING WHICH ENCOMPASSES WITHIN ITSELF SYS TEMATIC TRAINING, SCHOOLING AND INSTRUCTION. AS APPARENT FROM THE FAC TS OF THE CASE, THE APPELLANT IS PROVIDING SYSTEMATIC TRAINING IN THE F IELD OF COMMUNICATION. THE TRAINING IS IN NATURE OF CLASS ROOM TRAINING WI TH DEFINED COURSE CONTENTS AND OBJECTIVES AND AT THE END OF EACH CO URSE, THE RECOGNITION IS CONFERRED BY THE APPELLANT UPON THE PARTICIPANT OF THE RESPECTIVE COURSE. FURTHER, THE FLAGSHIP COURSE OF THE APPELLANT BEING PGDM PROGRAMME IS BEING REGULATED BY THE AICTE. ACCORDINGLY, THE ACTI VITY CARRIED OUT BY THE APPELLANT CAN BE CLASSIFIED UNDER 'EDUCATION' UNDER SECTION 2(15) OF THE L.T.ACT AND CANNOT BE CONSIDERED TO BE 'ANY OTHER O BJECT OF ADVANCEMENT OF GENERAL PUBLIC UTILITY'. IN THIS REGARD, THE RAT IO OF THE DECISION OF THE HON' BLE GUJARAT HIGH COURT GUJARAT CO-OPERATIVE (SUPRA) AND HON'BLE SUPREME COURT IN LOKA SIKSHANA (SUPRA) IS RELEVANT.) 5.5 FURTHER, IT IS ALSO OBSERVED THAT, THE AHMEDABA D BENCH OF THE HON'BLE ITAT IN THE CASE OF AHMEDABAD MANAGEMENT ASSOCIATIO N, WHICH CONDUCTS SHORT MANAGEMENT COURSES WHICH ARE NOT EVEN RECOGNI ZED BY AICTE, HAS HELD THAT MERE EARNING OF SURPLUS CANNOT BE CONSIDE RED AS REASON FOR CONSIDERING EDUCATIONAL ACTIVITY UNDER 'ANY OTHER O BJECT OF ADVANCEMENT OF ITA NO. 1910/AHD/2016 DCIT VS. MUDRA FOUNDATION FOR COMM. RESEARCH & EDN ASSESSMENT YEAR: 2012-13 PAGE 3 OF 5 GENERAL PUBLIC UTILITY' AND APPLY PROVISO TO SECTIO N 2(15) OF THE L.T. ACT. THE APPELLANT HAS ALSO SUBMITTED THAT THE DLT(EXEMPTION ), BASED ON THE FINDING OF THE IMPUGNED ASSESSMENT ORDER HAD INITIATED PROC EEDING U/S 12AA(3) , BUT HAS DROPPED THE PROCEEDINGS VIDE ORDER NO DLT(E )/12AA/MUDRA?12- 13/1077 DATED 03/03/2014. 5.6 ACCORDINGLY, IT IS HELD THAT, THE ACTIVITY OF T HE APPELLANT IS IN NATURE OF 'EDUCATION' WHICH IS INCLUDED IN DEFINITION OF 'CHA RITABLE PURPOSE' AS PER SECTION 2(15) OF THE L.T. ACT AND HENCE INCOME OF T HE APPELLANT IS TO BE COMPUTED AS PER THE PROVISIONS OF SECTION 11(1) OF THE ACT. THEREFORE, THE ADDITION OF RS. 2,72,17,916/- IS HEREBY DELETED. 11. WE FURTHER OBSERVE THAT HONBLE JURISDICTIONAL HIGH COURT IN THEIR ORDERS DATED 28-29/07/2015 VIDE SPECIAL LEAVE APPLICATION NO.6086/2015 HAS HELD THAT THE INSTITUTION RUN BY THE ASSESSEES TRUST IS ESTA BLISHED FOR THE SOLE PURPOSE OF IMPARTING EDUCATION IN THE SPECIALIZED FIELD AND TH E ACTIVITIES ARE COVERED UNDER THE PROVISIONS OF SECTION 2(15) OF THE ACT AND ACCO RDINGLY IS ELIGIBLE FOR EXEMPTION U/S.11(1)(A) OF THE ACT. WE FURTHER FIND THAT REVEN UES SLP FILED BEFORE THE HONBLE APEX COURT AGAINST THE JUDGMENT OF HONBLE JURISDICTIONAL HIGH COURT REFERRED ABOVE ALSO STANDS DISMISSED BY THE ORDER D ATED 10/05/2016 IN SUPREME COURT IN CIVIL APPEAL NO.5040 OF 2016. 12. WE THEREFORE RESPECTFULLY FOLLOWING THE JUDGMEN T OF JURISDICTIONAL HIGH COURT AND IN THE GIVEN FACTS AND CIRCUMSTANCES OF T HE CASE ARE OF THE CONSIDERED VIEW THAT ASSESSEE ACTIVITIES OF IMPARTING EDUCATIO N ARE CHARITABLE IN NATURE AS PROVIDED IN SECTION 2(15) OF THE ACT. WE THEREFORE FIND NO REASON TO INTERFERE WITH THE FINDINGS OF LD.CIT(A) AND UPHELD THE SAME. ACCO RDINGLY GROUND NO.1, 2 AND 3 OF THE REVENUES APPEAL ARE DISMISSED. 13. NOW WE TAKE UP SECOND ISSUE RAISED BY THE REVE NUE IN GROUND NO.4 AGAINST THE ORDER OF LD.CIT(A) DELETING DISALLOWANC E OF CAPITAL EXPENDITURE OF RS.1,34,89,333/- INCURRED BY THE ASSESSEE AND CLAI MED TO HAVE BEEN APPLIED FOR CHARITABLE PURPOSE U/S.11(1)(A) OF THE ACT. 14. LEARNED DEPARTMENTAL REPRESENTATIVE SUPPORTED T HE ORDER OF LD.AO AND LD. AR REITERATED THE SUBMISSION MADE BEFORE LD.CIT (A) AND THE FINDING OF LD.CIT(A) THEREOF. 15. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSED THE RECORDS PLACED BEFORE US. WE HAVE DISMISSED THE REVENUES GROUND N O.1,2 AND 3 BY FOLLOWING THE JUDGMENT OF JURISDICTIONAL HIGH COURT IN ASSESS EES OWN CASE AND ACCEPTED THAT ITS ACTIVITIES OF PROVIDING EDUCATION ARE OF C HARITABLE IN NATURE AND ARE COVERED UNDER THE PROVISION OF SECTION 2(15) OF THE ACT AND THEREFORE THE EXPENDITURE INCURRED BY THE ASSESSEE TOWARDS ATTAIN MENT OF THE OBJECTIVES OF PROVIDING EDUCATION ARE TO BE CONSIDERED TO HAVE BE EN APPLIED FOR CHARITABLE PURPOSE. 16. WE FURTHER OBSERVE THAT PROVISION OF SECTION 11 (1)(A) CONTEMPLATES THAT, INCOME DERIVED FROM PROPERTY (WHICH IN THIS CASE IS FROM RUNNING EDUCATIONAL INSTITUTION) HELD UNDER TRUST WHOLLY FOR CHARITABL E OR RELIGIOUS PURPOSE TO THE EXTENT, WHICH SUCH INCOME IS APPLIED TO SUCH PURPOS ES IN INDIA AND WHETHER ANY SUCH INCOME IS ACCUMULATED OR SET APART FOR APPLICA TION TO SUCH PURPOSES IN INDIA TO THE EXTENT TO WHICH THE INCOME SO ACCUMULATED O R SET APART WOULD NOT IN EXCESS OF THE 15% OF THE INCOME FROM SUCH PROPERTY THAN SUCH INCOME IS NOT TO ITA NO. 1910/AHD/2016 DCIT VS. MUDRA FOUNDATION FOR COMM. RESEARCH & EDN ASSESSMENT YEAR: 2012-13 PAGE 4 OF 5 BE INCLUDED IN THE TOTAL INCOME OF THE PREVIOUS YE AR OF THE PERSON IN RESPECT OF SUCH INCOME. 17. IN LIGHT OF ABOVE PROVISION, LET US EXAMINE THE ISSUE THAT, WHETHER THE CAPITAL EXPENDITURE OF RS.1,34,89,333/- INCURRED BY THE ASSESSEE IS ELIGIBLE FOR EXEMPTION U/S.11(1)(A) OF THE ACT. WE FIND THAT ASS ESEE INCURRED CAPITAL EXPENDITURE OF RS.1,34,89,333/- AND CLAIMED IT AS A N EXPENDITURE AGAINST THE INCOME. WE FURTHER FIND THAT ASSESSEE HAS ADDED BAC K THE DEPRECIATION OF RS.61,07,021/- DEBITED TO THE PROFIT AND LOSS ACCOU NT TO THE INCOME IN THE COMPUTATION OF INCOME. THERE IS NO DISPUTE TO THE F ACTS THAT ASSESSEE IS NOT CARRYING ANY OTHER ACTIVITIES OTHER THAN PROVIDING EDUCATION. IT IS ALSO NOT DISPUTED THAT THE CAPITAL EXPENDITURE OF RS.1,34,89,333/- HA S BEEN MADE FOR PURCHASING ASSET TO BE USED FOR THE PURPOSE OF PROVIDING EDUCA TION. WE ARE THEREFORE OF THE VIEW THAT THE CAPITAL EXPENDITURE INCURRED AT RS.1, 34,89,333/- SQUARELY FALLS IN THE PROVISION OF SECTION 11(1)(A) OF THE ACT WHICH PROV IDES FOR DEDUCTION AGAINST THE INCOME. OUR VIEW FURTHER FIND SUPPORT FROM THE JUDG MENT OF JURISDICTIONAL HIGH COURT IN THE CASE OF SATYA VIJAY PATEL HINDU DHARAM SHALA TRUST VS. CIT 86 ITR 683 WHEREIN HONBLE COURT OBSERVED AS FOLLOWS: AS REGARDS THE CONTENTION WHETHER THE WHOLE OF THE NET SURPLUS INCOME OF THE TRUST PROPERTIES APPLIED IN CONSTRUCTING THE NE W DHARAMSHALA OR ONLY EQUIVALENT TO 25 PER CENT OF THE NET INCOME WOULD B E EXEMPT FROM TAX, THE DOMINANT OBJECT OF CREATING THE TRUST BEING TO ESTA BLISH DHARAMSHALA FOR THE BENEFIT OF HINDUS, THE UTILISATION OF NET SURPL US INCOME OF THE TRUST PROPERTIES IN THE CONSTRUCTION OF THE NEW DHARAMSHA LA, EVEN IF IT EXCEEDED TWENTY-FIVE PER CENT OF THE NET INCOME OF THE TRUST PROPERTIES, COULD NOT BE SAID TO BE APPLICATION TO PURPOSES OTHER THAN THE C HARITABLE PURPOSES OF THE TRUST. SO LONG AS THE APPLICATION OF THE NET SU RPLUS INCOME OF THE TRUST PROPERTIES TO THE CONSTRUCTION OF THE NEW DHARAMSHA LA COULD NOT BE SAID TO BE OUTSIDE THE PURPOSES OF THE TRUST, AND INDEED IT COULD NOT BE, FOR, OTHERWISE IT WOULD AMOUNT TO BREACH OF TRUST WHICH IT WAS CLEARLY NOT, AND WHICH EVEN THE REVENUE DID NOT ALLEGE, IT MUST BE H ELD THAT THE APPLICATION WAS TO THE CHARITABLE PURPOSES OF THE TRUST. THE WH OLE OF THE NEW SURPLUS INCOME OF THE TRUST PROPERTIES WAS, THEREFORE, CLEA RLY APPLIED TO THE CHARITABLE PURPOSES FOR WHICH THE TRUST PROPERTIES WERE HELD BY THE TRUSTEES AND WAS ACCORDINGLY EXEMPT FROM TAX UNDER SECTION 11, SUB- SECTION (1), CLAUSE (A).' 18. WE THEREFORE RESPECTFULLY FOLLOWING THE JUDGMEN T OF JURISDICTIONAL HIGH COURT AND IN THE GIVEN FACTS AND CIRCUMSTANCES OF T HE CASE FIND NO REASON TO INTERFERE IN THE FINDINGS OF LD.CIT(A) WHO HAS DELE TED DISALLOWANCE BY OBSERVING AS FOLLOWS: 6.2 I HAVE CONSIDERED THE ASSESSMENT ORDER AND THE SUBMISSIONS MADE BY THE APPELLANT. SINCE THE APPELLANT WAS CLAI MING EXEMPTION UNDER SECTION 11 OF THE ACT IN RESPECT OF INCOME APPLIED FOR CHARITABLE PURPOSES, IN THE RETURN OF INCOME, THE APPELLANT HAD CLAIMED THE EXEMPTION IN RESPECT OF CAPITAL EXPENDITURE OF RS.1,34,89,333/- AS APPLICATION OF INCOME FOR CHARITABLE PURPOSES. THE AO HAS HELD THAT AS PE R NORMAL ACCOUNTING PRINCIPLES THE EXPENSES HAVE TO BE SPREAD OVER THE USEFUL LIFE OF THE FIXED ASSETS OR EXPENSES OF CAPITAL IN NATURE TO ARRIVE A T TRUE AND CORRECT OF ANY INSTITUTION. THE HON'BLE SUPREME COURT IN THE CASE OF S.RM.M.CT.M. TIRUPPANI TRUST 96 TAXMAN 635 WHEREBY EXPENDITURE I NCURRED FOR CONSTRUCTION OF BUILDING WAS CONSIDERED AS HAVING B EEN APPLIED FOR CHARITABLE PURPOSES AND SUCH INCOME APPLIED WAS HEL D TO BE EXEMPT. ITA NO. 1910/AHD/2016 DCIT VS. MUDRA FOUNDATION FOR COMM. RESEARCH & EDN ASSESSMENT YEAR: 2012-13 PAGE 5 OF 5 FURTHER, THE HON'BLE GUJARAT HIGH COURT IN THE CASE OF SATYA VIJAY PATEL HINDU DHARAMSHALA TRUST(SUPRA) HAS ALSO HELD THAT I NCOME APPLIED FOR CONSTRUCTION OF NEW DHARMASHALAS WAS APPLICATION OF INCOME FOR CHARITABLE PURPOSES AND ACCORDINGLY, INCOME SO APPLIED WAS EXE MPT UNDER SECTION 11[1] (A) OF THE ACT. ACCORDINGLY, CONSIDERING THE FACT THAT THE APPELLANT IS ELIGIBLE TO EXEMPTION UNDER SECTION 11 TO 13 OF THE ACT AND FOLLOWING THE RATIO LAID DOWN BY HON'BLE SUPREME COURT AND THE GU JARAT HIGH COURT, THE ADDITION OF RS.1,34,89,333/- BEING CAPITAL EXPENDI TURE INCURRED BY APPELLANT DURING THE YEAR IS HEREBY DELETED. HOWEVE R, SINCE NET ADDITION MADE BY THE AO AFTER GRANTING DEPRECIATION TO THE A PPELLANT IS OF THE ORDER OF RS.73,82,312/- THE SAME IS DIRECTED TO BE DELETE D. 19. ACCORDINGLY GROUND NO.4 OF THE REVENUE IS DISMI SSED. GROUND NO.5 IS GENERAL IN NATURE WHICH NEEDS NO ADJUDICATION. 4. WE SEE NO REASONS TO TAKE ANY OTHER VIEW OF THE MATTER THAN THE VIEW SO TAKEN BY THE CO-ORDINATE BENCH. RESPECTFULLY FOLLOW ING THE VIEWS SO TAKEN BY THE CO- ORDINATE BENCH (SUPRA) IN ASSESSEES OWN CASE FOR A Y 2009-10 IN ITA NO.1644/AHD/2014, WE REJECT THE GRIEVANCES OF THE A SSESSING OFFICER. 5. IN THE RESULT, THE APPEAL OF THE REVENUE IS DISM ISSED. PRONOUNCED IN THE OPEN COURT TODAY ON THE 18 TH APRIL, 2018 SD/- SD/- RAJPAL YADAV PRAMOD KUMAR (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) AHMEDABAD, THE 18 TH DAY OF APRIL, 2018 **BT COPIES TO: (1) THE APPELLANT (2) THE RESPONDENT (3) COMMISSIONER (4) CIT(A) (5) DEPARTMENTAL REPRESENTATIVE (6) GUARD FILE BY ORDER TRUE COPY ASSISTANT REGISTRAR INCOME TAX APPELLATE TRIBUNAL AHMEDABAD BENCHES, AHMEDABAD 1. DATE OF DICTATION: ................COVERED MATT ER...17.04.2018... 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE T HE DICTATING MEMBER: ....... 17.04.2018.......... 3. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR . P.S./P.S.: 18.04.2018... 4. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE TH E DICTATING MEMBER FOR PRONOUNCEMENT: .... 18.04.2018... 5. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK : .. 18.04.2018 6. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK : . 7. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT RE GISTRAR FOR SIGNATURE ON THE ORDER : 8. DATE OF DESPATCH OF THE ORDER: ......