The ACIT, Circle-8, Ahmedabad V. The Sports Club Of Gujarat Ltd., Ahmedabad

ITA 2239/AHD/2011

• Counselvise Citation: [2016] 133 COUNSELVISE.COM (IT) 1528 (ITAT-AHMEDABAD)
• Duration Of Justice: 4 year(s) 8 month(s) 15 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 20-05-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 17-05-2016
• Assessment Year: 2008-2009
• Appeal Filed On: 05-09-2011
• Result in Favour of: Assessee
• Court: TRIBUNAL

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH, AHMEDABAD , , ! BEFORE SHRI SHAILENDRA KUMAR YADAV, JUDICIAL MEMBER AND SHRI ANIL CHATURVEDI, ACCOUNTANT MEMBER SL. NO(S) ITA/CO NO(S) ASSESSMENT YEAR(S) APPEAL(S) /CO BY APPELLANT S VS. RESPONDENTS APPELLANT RESPONDENT 1. 2239/AHD/2011 2008 - 09 ACIT CIR.8 AHMEDABAD THE SPORTS CLUB OF GUJARAT LTD. SARDAR PATE STADIUM NAVRANGPURA AHMEDABAD PAN:AAACT 7280 N 2. 1467/AHD/2012 2009 - 10 THE ITO WARD-8(2) AHMEDABAD THE SPORTS CLUB OF GUJARAT LTD. -SAME ADDRESS- 3 . CO NO.195/AHD/11 ( IN ITA NO.2239/AHD/11 ) 2008 - 09 THE SPORTS CLUB OF GUJARAT LTD., AHMEDABAD THE ACIT CIR.8 AHMEDABAD 4 . CO NO.133/AHD/12 ( IN ITA NO.1467/AHD/12 ) 2009 - 10 THE SPORTS CLUB OF GUJARAT LTD., AHMEDABAD THE ITO WARD-8(2) AHMEDABAD REVENUE BY : SHRI ALBINUS TIRKEY, SR.DR ASSESSEE BY : SHRI ANIL R. SHAH, AR ' # / DATE OF HEARING 17/05/2016 $%&' # / DATE OF PRONOUNCEMENT 20/05/2016 / O R D E R PER SHRI ANIL CHATURVEDI, ACCOUNTANT MEMBER : THESE TWO APPEALS BY THE REVENUE ARE DIRECTED AGA INST THE SEPARATE ORDERS OF THE COMMISSIONER OF INCOME TAX(APPEALS)-I V, AHMEDABAD ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 2 - DATED 27/06/2011 FOR AY 2008-09 AND DATED 3/04/20 14 FOR AY 2009-10. THE ASSESSEE IS IN CROSS-APPEALS THEREOF. 2. BEFORE US, BOTH THE PARTIES SUBMITTED THAT THOUGH T HE APPEALS RELATE TO DIFFERENT ASSESSMENT YEARS, BUT THE FACTS IN BOT H THE APPEALS ARE IDENTICAL EXCEPT FOR THE ASSESSMENT YEAR AND THE AM OUNTS INVOLVED AND THE SUBMISSIONS MADE BY THEM WHILE ARGUING ONE CASE WOULD BE APPLICABLE TO THE OTHER APPEAL ALSO. IN VIEW OF THE AFORESAID SUBMISSIONS, WE FOR THE SAKE OF CONVENIENCE, PROCEE D TO DISPOSE OF ALL THE APPEALS BY WAY OF A CONSOLIDATED ORDER. WE THU S PROCEED WITH THE FACTS FOR AY 2008-09. 3. THE RELEVANT FACTS AS CULLED OUT FROM THE MATERI ALS ON RECORD ARE AS UNDER:- 3.1. ASSESSEE IS A CLUB WHO ELECTRONICALLY FILED IT S RETURN OF INCOME FOR AY 2008-09 ON 27/09/2010 DECLARING TOTAL INCOME OF RS. 13,47,940/-. THE CASE WAS SELECTED FOR SCRUTINY AND THEREAFTER ASSESSMENT WAS FRAMED U/S.143(3) OF THE I.T.ACT, 1961 VIDE ORDER DATED 27/12/2010 AND T HE TOTAL INCOME WAS DETERMINED AT RS.98,52,945/-. AGGRIEVED BY THE OR DER OF THE AO, ASSESSEE CARRIED THE MATTER BEFORE THE LD.CIT(A), WHO VIDE O RDER DATED 27/06/2011 (IN APPEAL NO.CIT(A)XIV/AC.CIR.8/178/2010-11) ALLOWED T HE APPEAL OF THE ASSESSEE. AGGRIEVED BY THE ORDER OF THE LD.CIT(A), REVENUE IS NOW IN APPEAL BEFORE US AND HAS RAISED THE FOLLOWING COMMON GROUN DS:- ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 3 - 1) THE LD.COMMISSIONER OF INCOME-TAX (APPEALS)-XI V, AHMEDABAD HAS ERRED IN LAW AND ON FACTS IN DELETING THE ADDIT ION OF RS.85,05,005/- MADE BY THE ASSESSING OFFICER ON ACCOUNT OF INCOME RECEIVED BY THE ASSESSEE FROM OUTSIDERS/NOT REGULAR MEMBERS/TEMPORA RY MEMBERS IN RESPECT OF GUEST FEES, INCOME FROM HIRE OF ROOM, HI RE CHARGES IN RESPECT OF CLUB LAWN. 2) ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CA SE, THE LD.COMMISSIONER OF INCOME-TAX (APPEALS)XIV, AHMEDAB AD OUGHT TO HAVE UPHELD THE ORDER OF THE ASSESSING OFFICER. 3.2. ASSESSEE HAS RAISED THE FOLLOWING COMMON GROUN DS (EXCEPT AMOUNT) IN ITS CROSS OBJECTIONS: 1. THE LEARNED CIT(A) HAS RIGHTLY HELD THAT AS PER FACTS OF THE CASE AND AS PER PROVISIONS OF LAW RS.85,05,005/- DERIVED AS INCOME BY THE RESPONDENT FROM ITS MEMBERS INCLUDING TEMPORARY MEM BERS GUEST FES INCOME FROM HIRE OF ROOM, HIRE CHARGES IN RESPECT O F CLUB LAW IS EXEMPT ON PRINCIPAL OF MUTUALITY AND THEREFORE THE APPEAL FILED BY THE DEPARTMENT IS REQUIRED TO BE DISMISSED. 2. (A) THE HON.TRIBUNAL FROM YEAR TO YEAR AND FRO M A.Y. 03-04 TO A.Y. 05-06 AND ALSO A.Y. 07-08 HAVE ACCEPTED THE AB OVE PRINCIPLE AND HAVE HELD THAT THE INCOME BY THE ASSE SSING OFFICER WAS NOT CORRECT IT BEING EXEMPT ON PRINCIPLE OF MUT UALITY. (B) IT IS FURTHER SUBMITTED THAT QUESTION REGARDIN G PRINCIPAL OF MUTUALITY AND INCOME BEING EXEMPT HAVING BEEN SETTL ED AND ACCEPTED BY THE INCOME-TAX DEPARTMENT FOR MORE THAN 30 YEARS IN VIEW OF PRINCIPAL LAID DOWN BY HON.SUPREME COURT IN THE CASE OF U.O I VS. KAUMUDINI NARAYAN DALAL REPORTED IN 24 5 ITR PAGE 219 APPEAL FILED BY THE DEPARTMENT IS REQUIRED TO B E HELD. INFRUCTUOUS AND THEREFORE IS LIABLE TO BE DISMISSED . ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 4 - 4. FIRST, WE TAKE REVENUES APPEAL FOR AY 2008-09. 4.1. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE AO NOTICED THAT THE ASSESSEE HAD COLLECTED FOLLOWING SUMS OF MONEY :- SL.NO. NATURE OF INCOME AMOUNT (IN RS.) 1. GUEST FEES FROM MEMBERS 5,49,652 2. HIRE CHARGES FROM MEMBERS IN RESPECT OF CLUB PROPERTY 10,98,914 3. INCOME FROM ROOMS 68,56,439 TOTAL 85,05,005 4.2. THE ASSESSEE WAS ASKED TO SHOW-CAUSE NOTICE AS TO WHY THE ABOVE REFERRED SUMS NOT BE TAXED AS INCOME OF THE ASSESSE E. THE SUBMISSION OF THE ASSESSEE ABOUT IT BEING NON-TAXABLE ON ACCOUNT OF THE CONCEPT OF MUTUALITY WAS NOT FOUND ACCEPTABLE TO THE AO. HE A LSO NOTICED THAT IN AY 2007-08, AO WHILE FRAMING THE ASSESSMENT HAD CON SIDERED SIMILAR RECEIPTS, NAMELY, RECEIPTS FROM GUEST FEES, ROOM FE ES AND HIRE CHARGES AS TAXABLE INCOME OF THE ASSESSEE. AO, THEREFORE, FO R THE IMPUGNED YEAR ALSO CONSIDERED THE AGGREGATE SUM OF RS.85,05,005/- AS INCOME OF THE ASSESSEE. AGGRIEVED BY THE ORDER OF THE AO, ASSESS EE CARRIED THE MATTER BEFORE THE LD.CIT(A), WHO DECIDED THE ISSUE IN FAVO UR OF ASSESSEE BY HOLDING AS UNDER:- 4. DECISION I HAVE CAREFULLY PERUSED THE ASSESSMENT ORDER AND T HE WRITTEN SUBMISSION FILED BY THE LD.AR OF THE APPELLANT. T HE ISSUE IS REGARDING ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 5 - TREATMENT OF GUEST FEES. HIRE OF ROOM AND HIRE CHAR GES IN RESPECT OF CLUB LAWNS AGGREGATING TO RS.85,05,005/- RECEIVED FROM O UTSIDERS I.E. NON- MEMBERS OUTSIDE THE PRINCIPLES OF MUTUALITY. THE A SSESSING OFFICER TREATED THE ENTIRE INCOME AS TAXABLE. IT HAS BEEN POINTED OUT BY THE LD.AR THAT THE ISSUE IS DIRECTLY COVERED BY THE ORD ERS OF ITAT, AHMEDABAD IN APPELLANTS OWN CASE FOR ASSESSMENT YE ARS FROM AY 2004-05 TO 2007-08. HE HAS ALSO SUBMITTED COPY OF THE ORDER OF THE ITAT. I HAVE CAREFULLY PERUSED THE ORDER OF THE HO NBLE ITAT SUBMITTED BY THE APPELLANT. THE SUBMISSION MADE BY THE APPEL LANT IS CORRECT. THE HONBLE ITAT HAS HELD THAT THE ASSESSEE WAS ENTITLE D FOR THE BENEFIT OF DOCTRINE OF MUTUALITY AS THE HIRE CHARGES WERE RECE IVED FROM THE GUESTS OF THE MEMBERS. RESPECTFULLY FOLLOWING THE DECISIO N OF HONBLE ITAT IN APPELLANTS OWN CASE, THE ADDITION MADE BY THE ASSE SSING OFFICER ON ACCOUNT OF GUEST FEES, HIRE OF ROOMS AND HIRE CHARG ES IN RESPECT OF CLUB LAWS AGGREGATING TO RS.85,05,005/- IS DELETED. 4.3. AGGRIEVED BY THE ORDER OF THE LD.CIT(A), REVEN UE IS NOW IN APPEAL BEFORE US. 5. BEFORE US, LD.SR.DR SUPPORTED THE ORDER OF THE A O AND FURTHER RELIED ON THE JUDGEMENT OF HONBLE JURISDICTIONAL H IGH COURT IN THE CASE OF GUJARAT CLUB OF GUJARAT LTD. VS. CIT REPORTED AT (1988) 171 ITR 504 (GUJARAT). ON THE OTHER HAND, LD.AR SUPPORTED TH E ORDER OF THE LD.CIT(A) AND FURTHER SUBMITTED THAT IDENTICAL ISSU E AROSE IN ASSESSEES OWN CASE IN EARLIER YEARS. THE COORDINATE BENCH (I TAT B BENCH AHMEDABAD) OF TRIBUNAL WHILE DECIDING THE APPEAL (R EVENUES APPEAL) FOR AY 2006-07 IN ITA NO.296/AHD/2010 (WITH CO NO.6 4/AHD/2010) DATED 11/01/2013 AND BY FOLLOWING THE TRIBUNALS OR DER IN ASSESSEES ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 6 - OWN CASE FOR AYS 2003-04 & 2004-05 (ITA NOS.2793/AH D/2006 AND 1398/AHD/2007) HAD DISMISSED THE REVENUES APPEAL A ND THUS DECIDED THE ISSUE IN FAVOUR OF ASSESSEE. HE THEREFORE SUBM ITTED THAT SINCE THE FACTS OF THE CASE IN THE YEAR UNDER CONSIDERATION A RE SIMILAR TO AY 2006- 07 AND IN THE ABSENCE OF ANY CHANGE OF FACTS, THE O RDER OF LD.CIT(A) NEEDS BE UPHELD. AS FAR AS THE RELIANCE PLACED B Y THE LD.SR.DR ON THE JUDGEMENT OF HONBLE JURISDICTIONAL HIGH COURT IN T HE CASE OF SPORTS CLUB OF GUJARAT LTD. VS. CIT (SUPRA) IS CONCERNED, HE SUBMITTED THAT THE ISSUE IN THAT CASE WAS AS TO WHETHER INTEREST RECEI VED BY THE ASSESSEE ON FIXED DEPOSITS MADE WITH BANKERS WERE EXEMPT AND TH US WAS ON DIFFERENT FACTS. HE THEREFORE SUBMITTED THAT THE FACTS IN TH OSE CASE ARE ENTIRELY DIFFERENT AND THEREFORE THE DECISION RELIED UPON BY REVENUE ARE NOT APPLICABLE TO THE PRESENT FACTS. 6. WE HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIAL AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHORITIES BELOW AS WELL AS THE JUDGEMENT/DECISION RELIED UPON BY TH E PARTIES. THE ISSUE IN THE PRESENT CASE IS WHETHERTHE RECEIPTS FROM GUEST FEES, INCOME FROM HIRE OF ROOMS, HIRE CHARGES IN RESPECT OF CLUB LAWN IS T O BE CONSIDERED EXEMPT BY FOLLOWING PRINCIPAL OF MUTUALITY. WE FIND THAT THE LD.CIT(A), FOLLOWING THE TRIBUNALS ORDER IN ASSESSEES OWN CA SE IN EARLIER YEARS, HELD THAT THE ASSESSEE WAS ENTITLED FOR THE BENEFIT ON THE BASIS OF DOCTRINE ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 7 - OF MUTUALITY. WE FURTHER FIND THAT THE COORDINATE BENCH OF TRIBUNAL IN ASSESSEES OWN CASE FOR AY 2006-07 VIDE ORDER DATED 11/01/2013 HAD DECIDED THE ISSUE IN FAVOUR OF ASSESSEE BY HOLDING AS UNDER:- 2. THE ONLY GROUND IN THIS APPEAL IS AGAINST THE D ISALLOWANCE OF RS.52,95,900/-MADE BY THE A.O. ON ACCOUNT OF GUEST FEES, ROOM CHARGES AND HIRE CHARGES IN RESPECT OF CLUB LAWN COLLECTION FROM NON-MEMBERS, BY HOLDING THAT THE INCOME EARNED FROM THE PERSONS WHO WERE NOT REGULAR MEMBERS OF THE CLUB WAS NOT OFFERED THOUGH IT WAS OUT OF PURVIEW OF MUTUALITY. LD. CIT(A) HAS DELETED THIS A DDITION BY OBSERVING AS UNDER:- 'I HAVE CAREFULLY CONSIDERED THE FACTS OF THE CASE AND THE SUBMISSIONS OF THE A.R. ALONG WITH THE CASE LAWS AS RELIED UPON, I AM INCLINED TO ACCEPT THE CONTENTION OF THE APPELLA NT SUPPORTED BY VARIOUS DECISIONS IN FAVOUR OF APPELLANT IN EAR LIER YEARS BY VARIOUS APPELLANT AUTHORITIES ON THE SAME ISSUE. EV EN BY SUBMISSION DATED 13-11-09, APPELLANT SUBMITTED LATE ST DECISION OF THE HON'BLE ITAT 'B' BENCH AHMEDABAD IN THE CASE OF APPELLANT ITSELF FOR A. Y. 03-04 AND A. Y. 04-05 (I TA NO.2793/AHD/2006 AND 1398/AHD/2007) WHEREIN HON'BLE ITAT VIDE ITS ORDER DT:30-10-2009 CONSIDERED THE SIMILAR DISALLOWANCE AND ADDITION IN RESPECTIVE YEARS AND AFTER TAKING I NTO ACCOUNT THE FACTUAL AND LEGAL POSITION AS WELL AS EARLIER YEAR' S APPELLATE ORDER IN THE, CASE OF APPELLANT AS WELL AS THE HON' BLE ITAT AHMEDABAD D BENCH DECISION DT:23-02-07 PASSED IN TH E CASE OF RAJPATH CLUB LTD. IN ITA NO.2830/AHD/2006 RELATING TO A.Y. 03- 04 ALLOWED THE APPEAL OF THE APPELLANT FOR DELETING SUCH ADDITIONS. IT IS, THEREFORE, RESPECTFULLY FOLLOWING SUCH DECISION, THE ADDITION SO MADE IS DIRECTED TO BE DELETED. THE APPELLANT GETS A RELIEF OF RS. 52,95,900/-.' ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 8 - 3. SINCE ID. CIT(A) HAS GIVEN RELIEF TO THE ASSESSE E BY PLACING RELIANCE ON THE DECISION OF HON'BLE ITAT IN ASSESSEE'S OWN C ASE FOR THE A.Y. 2003-04 AND 2004-05, WE FEEL NO NEED TO INTERFERE W ITH THE ORDER PASSED BY ID. CIT(A) AND THE SAME IS HEREBY UPHELD. 6.1. BEFORE US, REVENUE HAS NOT BROUGHT ANY CONTRAR Y BINDING DECISION IN ITS SUPPORT NOR HAS PLACED ANY MATERIAL ON RECOR D TO DEMONSTRATE THAT THE DECISIONS OF THE TRIBUNAL IN ASSESSEES OWN CAS E FOR AY 200-07 HAS BEEN SET ASIDE BY HONBLE JURISDICTIONAL HIGH COUR T. WE FURTHER FIND THAT RELIANCE PLACED BY THE REVENUE IN THE CASE OF SPORTS CLUB OF GUJARAT LTD. VS. CIT(SUPRA) ARE ON DIFFERENT FACTS AND, THE REFORE, THE RATIO OF THE JUDGEMENT IS NOT APPLICABLE TO THE FACTS OF THE PRE SENT CASE. IN VIEW OF THE AFORESAID FACTS, WE FIND NO REASON TO INTERFERE WITH THE ORDER OF THE LD.CIT(A) AND THUS THE GROUND OF REVENUE IS DISMISS ED. 6.2. THUS, APPEAL OF THE REVENUE FOR AY 2008-09 I S DISMISSED. 7. NOW, WE TAKE UP REVENUES APPEAL FOR AY 2009-10. 7.1. IN THIS CASE, SINCE BOTH THE PARTIES HAVE A DMITTED THAT THE FACTS AND CIRCUMSTANCES OF THE PRESENT CASE ARE IDENTICAL TO THAT OF ITA NO.2239/AHD/2011 FOR AY 2008-09 IN REVENUES APPEAL (SUPRA), WHICH WE HAVE DECIDED HEREINABOVE IN FAVOUR OF ASSESSEE, WE THEREFORE FOR THE SIMILAR REASONS STATED HEREINABOVE WHILE DECIDING T HE REVENUES APPEAL FOR A.Y. 2008-09 IN ITA NO.2239/AHD/2011 FOR AY 200 8-09 (SUPRA) AND ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 9 - FOR SIMILAR REASONS DISMISS THE GROUND OF REVENUE F OR 2009-10. RESULTANTLY, REVENUES APPEAL IN ITA NO.1467/AHD/1 2 FOR AY 2009-10 IS ALSO DISMISSED. 8. LASTLY, WE TAKE UP ASSESSEES CROSS OBJECTION NO S.195/AHD/2011 FOR AY 2008-09 AND 133/AHD/2012 FOR AY 2009-10. 8.1. BEFORE US, LD.AR SUBMITTED THAT HE DOES NOT WA NT TO PRESS THE CROSS OBJECTIONS FILED BY THE ASSESSEE. IN VIEW OF THE AFORESAID SUBMISSION OF LD.AR, THE COS ARE DISMISSED AS NOT P RESSED. 9. IN THE COMBINED RESULT, REVENUES APPEALS AND CR OSS OBJECTIONS FILED BY THE ASSESSEE ARE DISMISSED. THIS ORDER PRONOUNCED IN OPEN COURT ON 20 /05/2016 SD/- SD/- ( ) ( ) (SHAILENDRA KUMAR YADAV) ( ANIL CHATUR VEDI ) JUDICIAL MEMBER ACCOUNTANT MEMBER AHMEDABAD; DATED 20/ 05 /2016 ,.., .../ T.C. NAIR, SR. PS ITA NOS.2239/AH D/11 AND 1467/AHD/2012 BY REVENUE AND CO NOS.195/AHD/2011 AND 133/AHD/2012 (BY ASSESS EE) ACIT VS. THE SPORTS CLUB OF GUJARAT LTD. ASST.YEARS 2008-09 &2009-10 RESPECTIVELY - 10 - ! / COPY OF THE ORDER FORWARDED TO : 1. ./0 / THE APPELLANT 2. 12/0 / THE RESPONDENT. 3. 345 6 / CONCERNED CIT 4. 6 ( . ) / THE CIT(A)-XIV, AHMEDABAD 5. 789 145 , . 45 ' , 3 / DR, ITAT, AHMEDABAD 6. 9; <' / GUARD FILE. / BY ORDER, 27. 1 //TRUE COPY// / ( DY./ASSTT.REGISTRAR) , / ITAT, AHMEDABAD 1. DATE OF DICTATION .. 16.5.16 (DICTATION-PAD 11+ PAGES ATTACHED AT THE END OF THIS APPEAL-FILE) 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 19.5.16 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 BACK TO THE SR.P .S./P.S.20.5.16 7. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 20.5.16 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