The DCIT, Circle-2, JAMNAGAR V. Swastik Construction Co., JAMNAGAR

ITA 215/RJT/2013

• Counselvise Citation: [2015] 120 COUNSELVISE.COM (IT) 9516 (ITAT-RAJKOT)
• Duration Of Justice: 1 year(s) 9 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-02-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2009-2010
• Appeal Filed On: 08-05-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: AVINASH KUMAR
• Assessee Lawyers: P M MAHARSHI C A
• Keywords: Additional evidence; Onus to prove
• Section: 2

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBULAL, RAJKOT BENCH: RAJKOT .., ! ' #, $ % BEFORE SHRI N.S.SAINI, ACCOUNTANT MEMBER AND SHRI KUL BHARAT, JUDICIAL MEMBER &./ I.T.A. NO.215/RJT/2013 ( / ASSESSMENT YEAR : 2009-10) DY.CIT CIRCLE-2 JAMNAGAR / VS. SWASTIK CONSTRUCTION CO., PANCHMUKHI HANUMAN SHOPPING CENTRE NR.AMBER CINEMA JAMNAGAR ( & ./ ) & ./ PAN/GIR NO. : AAOFS 5978 B ( (* / APPELLANT ) .. ( +,(* / RESPONDENT ) (* - / APPELLANT BY : SHRI AVINASH KUMAR, SR.DR +,(* . - / RESPONDENT BY : SHRI P.M. MAHARSHI, C.A. ! / 0 . # / DATE OF HEARING 16/02/2015 12 . # / DATE OF PRONOUNCEMENT 18/02/2015 3 / O R D E R PER BENCH : THIS APPEAL BY THE REVENUE IS DIRECTED AGAINST T HE ORDER OF THE LD.COMMISSIONER OF INCOME TAX(APPEALS)-JAMNAGAR (CIT(A) IN SHORT) DATED 28/02/2013 FOR ASSESSMENT YEAR (AY) 2009-10. THE REVENUE HAS RAISED THE FOLLOWING GROUNDS OF APPEAL:- 1. THE CIT(A) ERRED IN LAW AND ON FACTS IN RESTRICTING THE ADDITION TO RS.7,55,110/- OUT OF THE TOTAL ADDITION OF RS.29,86,305/- MADE BY THE AO ON ACCOUNT OF UNPROVED SUNDRY CREDITORS. 2. THE CIT(A) ERRED IN LAW AND IN FACTS IN NOT APPRECIATING THE FACT THAT THE ASSESSEE HAD REMAINED NON-COOPERATIVE FOR MOST PART OF THE ASSESSMENT PROCEEDINGS AND THE ASSESSMENT HAD TO BE COMPLETED ITA NO.215/RJT/2013 DCIT, CC-2 JAMNAGAR VS. SWASTIK CONSTRUCTION CO., JAMNAGAR ASST.YEAR - 2009-10 - 2 - U/S.144 OF THE ACT, WHICH PREVENTED THE AO FROM VERIFYING ALL THE SUNDRY CREDITORS AND THAT THE ONUS TO PROVE GENUINENESS OF THE CREDITORS LIED ON THE ASSESSEE IN WHICH THE ASSESSEE FAILED MIS ERABLY. IT IS ALSO NOTEWORTHY THAT ONE OF THE CREDITORS HAD CATEGORICALLY DENIED TO HAVE MADE TRANSACTIONS WITH THE ASSESSEE WHEREAS TWO OTHER CREDITORS WERE ALSO NOT FOUND TO BE GENUINE EVEN TO THE CIT(A) AND AS SUCH, THE GENUINENESS OF ALL THE CREDITORS ARE NOT BEYOND DOUBT AND THE ASSESSEE MIGHT HAVE NON-COOPERATED THE AO FOR THIS VERY REASON TO PREVENT THE AO FROM CARRYING OUT FURTHER VERIFICATIONS. 3. THAT ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CASE, THE LD.CIT(A) OUGHT TO HAVE UPHELD THE ORDER OF THE ASSESSING OFFICER. 4. IT IS THEREFORE PRAYED THAT THE ORDER OF THE LD.CIT(A) BE SET AS IDE AND THAT OF THE ASSESSING OFFICER BE RESTORED. 5. THAT THE REVENUE CRAVES LEAVE TO ADD, AMEND, ALTER OR WITHDRAW ANY GROUNDS OF APPEAL. 2. BRIEFLY STATED FACTS ARE THAT THE CASE OF TH E ASSESSEE WAS PICKED UP FOR SCRUTINY ASSESSMENT AND THE ASSESSMENT U/S.144 OF THE INCOME TAX ACT,1961 (HEREINAFTER REFERRED TO AS THE ACT) WAS FRAMED VIDE ORDER DATED 27/12/2011, THEREBY THE ASSESSING OFFICER (AO IN SHORT) MADE ADDITION OF RS.29,86,305/- ON ACCOUNT OF SUNDRY CRE DITORS. THE ONLY EFFECTIVE GROUND IS AGAINST THE RESTRICTING THE ADD ITION TO RS.7,55,110/- OUT OF TOTAL ADDITION OF RS.28,865,305/- MADE BY TH E AO ON ACCOUNT OF UNPROVED SUNDRY CREDITORS. 3. THE LD.SR.DR STRONGLY SUPPORTED THE ORDER OF THE AO AND SUBMITTED THAT THE LD.CIT(A) WAS NOT JUSTIFIED IN RESTRICTING THE ADDITION. HE SUBMITTED THAT THE ASSESSEE WAS GIVEN SUFFICIENT OPPORTUNITY BY THE AO, BUT THE ASSESSEE CHOSE NOT TO GIVE EXPLANATION AS CALLED FOR. 3.1. ON THE CONTRARY, THE LD.COUNSEL FOR THE ASSESS EE SUBMITTED THAT THE AO HAS FAILED TO APPRECIATE THE FACT THAT OUT OF TE N PARTIES, RANDOMLY ITA NO.215/RJT/2013 DCIT, CC-2 JAMNAGAR VS. SWASTIK CONSTRUCTION CO., JAMNAGAR ASST.YEAR - 2009-10 - 3 - SELECTED SEVEN PERSONS BY THE AO AND THEY CONFIRMED THE CREDIT ENTRY AND OUT OF REMAINING THREE PERSONS, ONE PERSON DENIED F OR ANY CREDIT. HE SUBMITTED THAT THE ASSESSEE HAS DISCHARGED ITS ONUS BY PLACING ON RECORD THE LEDGER ACCOUNTS OF THE CONCERNED-PERSONS. HE F URTHER SUBMITTED THAT THE AO HAS VERIFIED ALL THE DETAILS AND HE HAS NOT POINTED OUT ANY DEFECT IN THE DETAILS SUBMITTED OR IN THE BOOKS OF ACCOUNT S SUBMITTED BY THE ASSESSEE. FURTHER, THE BOOKS OF ACCOUNTS ARE DULY VERIFIED BY THE CHARTERED ACCOUNTANT. HE FURTHER SUBMITTED THAT TH E AO HAS DISALLOWED THE LOSS WITHOUT REJECTING THE BOOKS OF ACCOUNTS. HE SUBMITTED THAT THE AO MERELY ON ESTIMATION BASIS MADE THE ADDITION TO THE EXTENT OF LOSS CLAIMED BY THE ASSESSEE OF RS.29,86,305/- WHICH IS NOT PERMISSIBLE UNDER THE LAW. 4. WE HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIAL AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHORITIES BELOW. WE FIND THAT THE LD.CIT(A) HAS GIVEN FINDING ON FAC T IN PARAS-6 TO 8 OF HIS ORDER, WHICH ARE REPRODUCED HEREUNDER:- 6. I HAVE CAREFULLY CONSIDERED THE OBSERVATIONS AND CONCLUSIONS OF THE ASSESSING OFFICER AND ALSO THE SUBMISSIONS MADE BY THE APPELLANT AGAINST THE DISALLOWANCE MADE BY THE AO IN THE ASSESSMENT ORDER. IT IS OBSERVED THAT THE AO STARTED HIS SCRUTINY BY EXAMINING GROSS PROFI T MARGIN OF THE BUSINESS ACTIVITIES OF THE APPELLANT. THE APPELLANT HAS SUBMITTED SEPARATE GROSS PROFIT MARGINS IN RESPECT OF THE TWO TYPES OF BUSINESS ACTIVITIES UNDERTAKEN BY IT AND ALSO HAS EXPLAINED THE REASONS FOR THE DECLINE IN GROSS PROFIT MARGINS. THE AO CONCLUDED THAT THE REASONS FURNISHED FOR THE MARGINAL DECLINE IN GROSS PROFIT DURING THE YEAR ARE NOT ACCEPTABLE WITHOUT ASSIGNING ANY SPECIFIC REASONS FOR NOT ACCEPTING THE EXPLANATIONS SUBMITTED BY THE APPELLANT. THE AO HAS ALSO NOT BEEN ABLE TO BRING ANY NEW EVIDENCE OR FINDING FROM EITHER THE ENQUIRY/EXAMINATION OF THE ACCOUNTS SO AS TO ARRIVE AT SUCH A CONCLUSION ITA NO.215/RJT/2013 DCIT, CC-2 JAMNAGAR VS. SWASTIK CONSTRUCTION CO., JAMNAGAR ASST.YEAR - 2009-10 - 4 - OR THE AUTHENTICITY OF THE BOOKS OF ACCOUNTS OF THE APPELLANT HAVE BEEN DOUBTED OR REJECTED DURING THE ASSESSMENT PROCEEDINGS. THE VERIFICATION OF SUNDRY CREDITORS MADE BY THE AO APPEARS TO HAVE PRIMARILY EMANATED FROM HIS PRIMA-FACIE DISBELIEF AND NON-ACCEPTANCE OF THE EXPLANATIONS GIVEN BY THE APPELLANT FOR THE DECLINE IN GROSS PROFI T DURING THE YEAR. IT IS OBSERVED THAT THE APPELLANT HAS FURNISHED A LIST OF 44 SUNDRY CREDITORS WHICH WERE OUTSTANDING IN THE BOOKS OF ACCOUNT AS AT THE END OF THE YEAR OUT OF WHICH, THE AO PICKED UP ONLY 10 CREDITORS FOR VERIFYING THEIR GENUINENESS. 6.1. SINCE THE AO DID NOT ACCEPT THE REASONS GIVEN BY THE APPELLANT FOR DECLINE IN GROSS PROFIT MARGIN AND STARTED WITH A PRESUMPTION THAT THE SUNDRY CREDITORS BALANCES OUTSTANDING IN THE BALANCE-SHEET IS ON A HIGHER SIDE, IT WOULD HAVE BEEN, IN THE FITNESS OF THINGS, APPROPRIATE FOR THE AO TO VERIFY THE BONAFIDE AND GENUINENESS OF ALL THE 44 SUNDRY CREDITORS SO THAT HIS SUSPICION ABOUT INFLATION OF PURCHASES COULD HAVE BEEN FACTUALLY VERIFIED AND TESTED AND APPROPRIATE EVIDENCE COULD HAVE BEEN BROUGHT INTO THE RECORD FOR MAKING PROPER ADDITION IN THE HANDS OF THE APPELLANT. HOWEVER, IN HIS WISDOM, THE AO CHOSE ONLY 10 CREDITORS OUT OF WHICH, MAJORITY NUMBERS I.E. 7 CREDITORS HAVE CONFIRMED THE BALANCES WHICH DID NOT AFFORD ANY SCOPE TO THE AO TO DOUBT THE TRANSACTION MADE BY THE APPELLANT WITH THEM. IN RESPECT OF REMAINING 3 PARTIES, THE LETTERS U/S.133(6) RETURNED UNSERVED FROM 2 PERSONS (SUN DRY CREDITORS) VIZ:- SHRI RAMDE SAMAT GOJIYA AND M/S.NEHA ENTERPRISE. ONLY ONE PERSON (SUNDRY CREDITOR), SHRI PARI RATILAL MANILAL IN WHOSE NAME A CREDIT BALANCE OF RS.1 LAC IS APPEARING IN THE BALANCE SHEET HAS STATED THAT NO AMOUNT IS RECEIVABLE BY HIM FORM THE APPELLANTS. 6.2 IN SUM, THE NET RESULT OF THE VERIFICATION EXERCISES CARRIED OUT BY THE AO WAS THAT ONLY ONE SUNDRY CREDITOR BEARING A BALANCE OF RS.1 LAC IN THE BOOKS OF APPELLANT DENIED ANY RECEIVABLE AMOUNT FROM THE APPELLANT, WHEREAS 7 PARTIES HAVE CONFIRMED THE TRANSACTION AND 2 PARTIES COULD NOT BE CONTACTED BY THE AO FOR VERIFICATION. THERE IS NO DOUBT THAT THE ONUS LIES ON THE APPELLANT TO PROVE THE GENUINENESS OF THE TRANSACTION IN RESPECT OF THOSE PARTIES WHOSE BONAFIDE ARE UNDER SUSPICION BY THE REVENUE. IN THIS CASE, THE ONUS LIES HEAVILY ON THE APPELLANT TO PROVE THE GENUINENESS OF THE TRANSACTION WITH SHRI PARI RATILAL MANILAL, IN WHOSE NAME A CREDIT BALANCE OF RS.1 LAC IS OUTSTANDING. IT WILL BE UNFAIR AND MISCARRIAGE OF JUSTICE EXPECT THE APPELLANT TO PROVE THE GENUINENESS OF ALL OTHER 34 SUNDRY CREDITORS WHO HAVE NOT BEEN DOUBTED BY THE AO AS IMPLICITLY INDICATED BY HIS ACTION OF NOT SENDING ANY LETTERS U/S.133(6 ) TO ITA NO.215/RJT/2013 DCIT, CC-2 JAMNAGAR VS. SWASTIK CONSTRUCTION CO., JAMNAGAR ASST.YEAR - 2009-10 - 5 - THEM OR WHO HAVE ALREADY COMPLIED WITH THE LETTERS BY CONFIRMING THE BALANCES (IN THIS CASE 7 SUNDRY CREDITORS WHO HAVE CONFIRMED). IT IS THEREFORE ILLOGICAL TO EXTRAPOLATE THE NEGATIVE REPLY RECEIVED FR OM ONLY ONE PERSON I.E. SHRI PARI RATILAL MANILAL (DENYING ANY AMOUNT RECEIVABLE FROM APPELLANT) TO THE ENTIRE PURCHASES OF THE APPELLANT AND DISALLOW THE EXPENDITURE ON A LUMP SUM MANNER TO THE EXTENT OF LOSS CLAIMED BY APPELLANT IN ITS RETURN OF INCOME. 7. COMING TO THE ONUS OF THE APPELLANT, BEFORE ME THE APPELLANT HAS FURNISHED LEDGER ACCOUNTS IN RESPECT OF SHRI PARI RATILAL MANILAL, SHRI RAMDEV SAMAT GOJIYA AND M/S.NEHA ENTERPRISES FROM 01.04.2009 ON ONWARDS. THE FINANCIAL YEAR UNDER CONSIDERATION HERE IS F.Y. 2008-09 (A.Y. 2009-10) HENCE, THE APPELLANT OUGHT TO HAVE SUBMITTED THE LEDGER ACCOUNT FROM 01.04.2008 ONWARDS, BUT THE APPELLANT HAS SUBMITTED THE LEDGER ACCOUNTS FROM 01.04.2009 PERHAPS WITH A VIEW TO SHOW THAT THE CREDIT BALANCES SHOWN OUTSTANDING AGAINST THESE THREE PARTIES HAVE BEEN SQUARED UP IN SUBSEQUENT YEARS. FROM THE LEDGER ACCOUNTS OF SHRI PARI RATILAL MANILAL IT IS OBSERVED THAT THE SAME DOES NOT CARRY PAN OF SHRI MANILAL. ALTHOUGH IT SHOWS THAT A PAYMENT OF RS.1 LAC MADE TO THE PARTY THROUGH CHEQUE ON OBC BANK ON 07-07-2012, THAT DOES NTO, IPSO FACTO, PROVE THAT THE MONEY HAS BEEN PAID TO SHRI MANILAL, HENCE, THE GENUINENESS OF THESE PAYMENTS STILL REMAINS TO BE PROVED. AS THE AO HAS MADE A CLEAR CUT FINDING ABOUT THE SUNDRY CREIDTORS THAT THE PARTY HIMSELF HAS DENIED IN WRITING HAVING ANY RECEIVABLE AMOUNT FROM THE APPELLANT AND THE APPELLANT HAS NOT CONT5ROVERTED IT BY SUBMITTING ANY REVERSE CONFIRMATION FROM THE PARTY, THE OUTSTANDING BALANCE OF RS.1 LAC AS ON 31-03-2009 HAS TO BE CONSIDERED AS NON-GENUINE AND BOGUS. AS REGARDS THE OTHER TWO SUNDRY CREIDTORS, VIZ. SHRI RAMDE SAMAT GOJIYA AND M/S.NEHA ENTERPRISE, IT WAS FOUND THAT THEIR LEDGER ACCOUNTS WERE NTO PRODUCED BY THE APPELLANT BEFORE THE AO DURING THE ASSESSMENT PROCEEDINGS HENCE, COPIES OF LEDGER ACCOUNTS OF THESE TWO SUNDRY CREDITORS WERE FORWARDED TO THE AO, I.E. ACIT, CIRCLE-2 JAMNAGAR, VIDE LETTER DATED 11/02/2013 REQUESTING HIM TO EXAMINE THESE ADDITIONAL EVIDENCES AND SUBMIT A FACTUAL REPORT THEREON. THE AO HAS SUBMITTED HIS OBSERVATIONS AND FINDINGS VIDE HIS LETTER DATED 28/02/2013. THE RELEVANT EXTRACTS OF AO FINDINGS ARE PRODUCED AS UNDER:- 1) M/S.NEHA ENTERPRISE : THE INSPECTOR MADE ALL OUT EFFORT TO TRACE THE SAID PARTY ON 23/02/2012, HOWEVER, IT IS REPORTED THAT ON LOCAL ENQUIRIES IT WAS GATHERED THAT NO SUCH PARTY EXISTED AT THE ADDRESS GIVEN. ITA NO.215/RJT/2013 DCIT, CC-2 JAMNAGAR VS. SWASTIK CONSTRUCTION CO., JAMNAGAR ASST.YEAR - 2009-10 - 6 - II) SHRI RAMDE SAMAT GOJIYA : THE INSPECTOR HAS REPORTED THAT THE SAID PARTY WAS CONTACTED ON 23/02/2013, WHO HAS INFORMED THAT HE HAD CARRIED OUT WORK FOR M/S.SWASTIK CONSTRUCTIONS. HOWEVER HE WAS ASKED TO FURNISH COPY OF THE LEDGER ACCOUNT OF THE PARTY AS APPEARING IN HIS BOOKS OF ACCOUNTS. THOUGH HE HAD ASSURED TO FURNISH THE SAME ON MONDAY I.E. 25/02/2013, TILL DATE HE HAS NEITHER ATTENDED IN PERSON AND FILED THE SAME, NOR HAS FURNISHED THROUGH HIS LEGAL REPRESENTATIVE OR ANY OTHER MODE. 5. IT IS PERTINENT TO NOTE THAT SHRI RAMDE SAMAT GOJIYA HAS STATED IN WRITING THAT HE HAD NOT CARRIED OUT ANY JOB FOR THE ASSESSEE FOR ANY OTHER YEARS BESIDES THE YEAR UNDER CONSIDERATION I.E. F.Y. 2008-09. BUT THE CASE OF M/S.SWASTIK CONSTRUCTIONS IS ALSO UNDER SCRUTINY FOR THE A.Y. 2010-11, WHEREIN IN THE LEDGER ACCOUNT FURNISHED OF EXCAVATION EXPENSES THE NAME OF RAMDE SAMAT GOJIYA APPEARS IN WHOSE NAME AN AMOUNT OF RS.13,51,800/- IS SHOWN TO HAVE BEEN DEBITED. 6. IT IS THEREFORE AMPLY CLEAR THAT THOUGH RAMDE SAMAT GOJIYA HAS CONFIRMED BEFORE THE INSPECTOR TO HAVE CARRIED OUT WORK DURING THE F.Y. 2009-10, SAME IS NOT TRUE. AS THE SAME PERSON HAS DENIED TO HAVE DONE ANY WORK IN ANY OTHER YEARS, BUT STILL HIS NAME APPEARS IN THE BOOKS OF ACCOUNTS OF THE ASSESSEE IN A.Y. 2010-11. 7. AS SUCH THE GENUINENESS OF THE PARTY AS ALSO MOST IMPORTANT BEING THE GENUINENESS OF THE TRANSACTION HAS NOT BEEN PROVED, AND THE ONUS ON THE ASSESSEE HAS REMAINED TO BE DISCHARGED. 8. GIVEN THE AFORESAID FACTUAL POSITION WITH RESPECT TO THE 3 SUNDRY CREDITORS, IT IS NOW CLEAR BEFORE ME THAT THE CREDIT BALANCES APPEARING AGAINST SHRI PARI RATILAL MANILAL, SHRI RAMDAS SAMAT GOJIYA & M/S.NEHA ENTERPRISE FOR RS.1 LAC, RS.5,69,111/- AND RS.86,000/- RESPECTIVELY ARE NOT GENUINE AND HENCE NEED TO BE DISALLOWED AND ADDED BACK. HOWEVER, THE ACTION OF THE AO DISALLOW EXPENDITURE TO THE EXTE NT OF RS.29,86,305/- ON A LUMP SUM BASIS WHICH IS EQUAL TO THE AMOUNT OF RETUNED LOSS, IS NOT JUSTIFIED OR MAINTAINABLE ON FACTS AND LAW. I, THEREFORE, RESTRICT THE DISALLOWANCE OF EXPENDITURE TO THE EXTENT OF RS.7,55,110/- COMPRISING THE THREE SUNDRY CREDITORS BALANCES IN RESPECT ITA NO.215/RJT/2013 DCIT, CC-2 JAMNAGAR VS. SWASTIK CONSTRUCTION CO., JAMNAGAR ASST.YEAR - 2009-10 - 7 - OF SHRI PARI RATILAL MANILAL, SHRI RAMDAS SAMAT GOJIYA AND M/S.NEHA ENTERPRISES AND THE REMAINING AMOUNT OF RS.22,31,195/- (RS.29,86,305 7,55,110) IS DELETED. 4.1. THE ABOVE FINDING OF THE LD.CIT(A) IS NOT CONT ROVERTED BY THE REVENUE BY PLACING ANY MATERIAL CONTRARY ON RECORD. FURTHER, ADMITTEDLY, THE AO HAS BASED THE ADDITION ON THE BA SIS OF ENQUIRY MADE DURING THE COURSE OF ASSESSMENT PROCEEDINGS. THE A SSESSEE WAS NOT CONFRONTED BY THE AO IN RESPECT OF THE ADVERSE EVID ENCE COLLECTED DURING THE COURSE OF ASSESSMENT PROCEEDINGS. UNDER THESE FACTS, WE DO NOT SEE ANY REASON TO INTERFERE WITH THE ORDER OF THE LD.CI T(A), SAME IS HEREBY UPHELD. 5. IN THE RESULT, THE APPEAL OF THE REVENUE IS DISM ISSED. ORDER PRONOUNCED IN THE COURT ON WEDNESDAY, THE 18 TH DAY OF FEBRUARY, 2015 AT RAJKOT. SD/- SD/- ( .. ) ( ! ' #) $ ( N.S. SAINI ) ( KUL BHARAT ) ACCOUNTANT MEMBER JUDICIAL MEMBER RAJKOT; DATED 18/ 02 /2015 .. , /.$../ T.C. NAIR, SR. PS ITA NO.215/RJT/2013 DCIT, CC-2 JAMNAGAR VS. SWASTIK CONSTRUCTION CO., JAMNAGAR ASST.YEAR - 2009-10 - 8 - / COPY OF THE ORDER FORWARDED TO : 1. (* / THE APPELLANT 2. +,(* / THE RESPONDENT. 3. &6& # ! 7# / CONCERNED CIT 4. ! 7# ( ) / THE CIT(A)-JAMNAGAR 5. 9/' : +$#$ , , /DR,ITAT, RAJKOT 6. : EF G 0 / GUARD FILE. / BY ORDER, , 9# +$# //TRUE COPY// !/ '# $% ( DY./ASSTT.REGISTRAR) # %&# ' , / ITAT, RAJKOT 1. DATE OF DICTATION .. 16.15(DICTATION-PAD 5-PA GES ATTACHED AT THE END OF THIS FILE) 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 17.2.15 3. OTHER MEMBER 4. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR.P. S./P.S.. 5. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE D ICTATING MEMBER FOR PRONOUNCEMENT 6. DATE ON WHICH THE FAIR ORDER COMES BAC K TO THE SR.P.S./P.S.18.2.15 7. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 18.2.15 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