The ACIT, Circle-1, Bhavnagar V. M/s. Vitcos Transportation Pvt. Ltd., Bhavnagar

ITA 2713/AHD/2014

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 8346 (ITAT-AHMEDABAD)
• Duration Of Justice: 3 year(s) 7 month(s) 7 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 16-05-2018
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 18-09-2017
• Assessment Year: 2010-2011
• Appeal Filed On: 09-10-2014
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Assessee Lawyers: MEHUL K PATEL
• Keywords: Depreciation; Business expenditure; Retrospective amendment; Revenue expenditure; Capital expenditure
• Section: 201(1)

Judgement Text

, , IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH, AHMEDABAD , , BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER & MS. MADHUMITA ROY, JUDICIAL MEMBER ./ I.T.A. NO.2713/AHD/2014 ( / ASSESSMENT YEAR : 2010-11) THE ACIT CIRCLE-1 BHAVNAGAR / VS. M/S.VICTOS TRANSPORTATION PVT.LTD. ABOVE KRISHNA MEDICAL STORE TOWER CHOWK AT: VALLABHIPUR, BHAVNAGAR # ./ ./ PAN/GIR NO. : AABCV 9914 G ( #% / APPELLANT ) .. ( &'#% / RESPONDENT ) #%( / APPELLANT BY : SHRI MUDIT NAGPAL, SR.DR &'#%)( / RESPONDENT BY : SHRI MEHUL K. PATEL, AR *+), / DATE OF HEARING 14/05/2018 -./0), / DATE OF PRONOUNCEMENT 16 / 05 /2018 / O R D E R PER MS. MADHUMITA ROY - JM: BEING AGGRIEVED BY AND/OR DISSATISFIED WITH THE OR DER DATED 22.07.2014 PASSED BY THE COMMISSIONER OF INCOME TAX(APPEALS)-X X, AHMEDABAD [LD.CIT(A) IN SHORT] FOR ASSESSMENT YEAR (AY) 2010 -11 ARISING OUT OF THE ASSESSMENT ORDER DATED 20.03.20 13 PASSED BY THE ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 2 - ACIT, CIRCLE-1, BHAVNAGAR, THE INSTANT APPEAL HAS B EEN FILED BEFORE US BY THE REVENUE WITH THE FOLLOWING GROUNDS:- 1. THE LD.CIT(A)-XX, AHMEDABAD HAS ERRED ON FACTS AND CIRCUMSTANCES OF THE CASE IN DELETING THE DISALLOWA NCE OF RS.18,74,523/- MADE U/S.40(A)(IA) OF THE ACT. 2. THE LD.CIT(A)-XX, AHMEDABAD HAS ERRED ON FACTS AND CIRCUMSTANCES OF THE CASE, RESTRICTING THE DISALLOW ANCE TO RS.1 LAC AND THEREBY ALLOWING RELIEF OF RS.86,000/- EVEN THOUGH THE ASSESSEE HAS FAILED TO GIVE ANY EVIDENCE OF CASH EX PENDITURE ON ACCOUNT OF REPAIRING EXPENSES OF RS.1,86,600/-. 3. THE LD.CIT(A)-XX, AHMEDABAD HAS ERRED ON FACTS AND CIRCUMSTANCES OF THE CASE IN ALLOWING THE EXPENDITU RE TO RS.16,25,011/- INCURRED FOR THE PURCHASE OF SEATS F OR NEWLY PURCHASED BUSES AS REVENUE EXPENDITURE. 2. GROUND NO.1 :- THE BRIEF FACTS LEADING TO THE GROUND IS THIS THAT THE ASSESSEE HAS MADE THE INTEREST PAYMENT OF RS.8, 65,018/- TO GE CAPITAL AND RS.10,09,505/- TO MAGMA FIN CORP LTD. T OTALLING TO RS.18,74,523/-. THE ASSESSING OFFICER ASSESSING O FFICER (AO) MADE THE DISALLOWANCE OF THE TOTAL AMOUNT OF RS.18,74,523/- ON THE PREMISE THAT NO TDS HAS BEEN MADE BY THE ASSESSEE WHILE MAKING THE CREDIT/PAYMENT OF THE INTEREST TO BOTH THE PARTIES INVOKING THE PROV ISIONS OF SECTION ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 3 - 40(A)(IA) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS 'THE ACT'). 3. THE LEARNED AR CONTENDED BEFORE US AT THE TIME OF HEARING THAT IT WAS A GENUINE OMISSION ON THE PART OF THE ASSESSEE FOR NOT MAKING THE TDS BUT BOTH THE RECIPIENTS OF THE INTEREST WAS AS SESSED TO TAX AND INTEREST INCOME HAS BEEN INCLUDED BY THEM WHILE COM PUTING THE TOTAL INCOME AND THE RETURNS OF INCOME WAS FILED FOR THE YEAR UNDER CONSIDERATION AND PAID THE TAXES THEREON. THE LEARN ED AR FURTHER ADDED THAT FORM NO. 26AR.W. RULE 31ACB DULY FILLED IN, AU DIT REPORT OF BOTH THE RECIPIENTS, ACKNOWLEDGMENTS OF THE RETURN OF IN COME OF BOTH THE RECIPIENTS FOR THE A. Y. 2010-11 ALONG WITH ALL OT HER CORRESPONDENCES AS PER THE REQUIREMENTS OF SECTION 201 SUB-SECTION (1) OF THE INCOME TAX ACT WERE PLACED ON RECORD AND THE CONDITION STIPULA TED UNDER THE NEWLY INSERTED PROVISO HAVE BEEN DULY COMPLIED WITH WHICH HAS NOT BEEN CONTROVERTED BY THE LEARNED DR. 4. WE HAVE HEARD THE RIVAL SUBMISSIONS MADE BY THE RESPECTIVE PARTIES, WE HAVE PERUSED THE RELEVANT MATERIALS AVA ILABLE ON RECORD. WE FIND THAT DURING THE COURSE OF APPELLATE PROCEEDING THE ASSESSEE ARGUED THAT BY THE FINANCE ACT 2012 SECOND PROVISO TO SEC TION 40(A)(IA) HAS BEEN INSERTED AND ACCORDING TO THAT IF THE ASSESSEE FAILED TO DEDUCT THE ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 4 - WHOLE/PART OF ANY TAX BUT THE SAME IS NOT DEEMED TO BE AN ASSESSEE IN DEFAULT UNDER THE 1 ST PROVISO TO SECTION 201(1) THEN IT SHALL BE DEEMED THAT THE ASSESSEE HAD DEDUCTED AND PAID TAXES ON SUCH SU M ON THE DATE OF FURNISHING OF RETURN OF INCOME BY THE PAYEE. 4.1. THE ISSUE HAS ALREADY BEEN EXAMINED BY THE H ONBLE ITAT IN THE CASE OF RAJEEV KUMAR AGARWAL IN ITA NO.337/AGRA/201 3 FOR THE ASSESSMENT YEAR 2006-07 WHERE IN AN IDENTICAL SITUA TION IT WAS HELD THAT NO DISALLOWANCE UNDER SECTION 40(A)(IA) IS CALLED F OR IN RESPECT OF THE NON-DEDUCTION OF TDS. MORE SO, IN VIEW OF THE APPLI CABILITY OF THE SECOND PROVISO OF SECTION 40(A)(IA) OF THE ACT WITH RETROSPECTIVE EFFECT. THE LEARNED AR FURTHER RELY UPON THE JUDGMENT OF CO MMISSIONER OF INCOME TAX-1 VS ANSAL LANDMARK TOWNSHIP (P) LTD WHE RE THE HONBLE DELHI HIGH COURT UPHELD THE RATIO OF THE JUDGMENT O F RAJEEV KUMAR AGARWAL (SUPRA). 4.2. TAKEN INTO CONSIDERATION OF THE ENTIRE A SPECT OF THE MATTER, WE DO NOT FIND ANY INFIRMITY IN THE ORDER PASSED BY THE L EARNED CIT(A) AND WE THUS DISMISS THE SAID GROUND OF APPEAL PREFERRED BY THE REVENUE. 5. GROUND NO. 2 :- THE BRIEF FACTS RELATIN G TO THE GROUND NO.2 IS THAT UPON VERIFICATION OF PROFIT AND LOSS ACCOUNT I T WAS NOTICED THAT THE ASSESSEE HAS CLAIMED REPAIRS & MAINTENANCE EXPENSES OF RS.18,65,960/-. ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 5 - CONSIDERING THE AMOUNT INVOLVED DETAILED INFORMATIO N IN THIS REGARD WAS CALLED FOR FROM THE ASSESSEE AND THE ASSESSEE SUB MITTED THE LEDGER ACCOUNTS OF REPAIRS AND MAINTENANCE EXPENSES AS ALS O SUPPORTING PROOF/EVIDENCES/BILLS/INVOICES WHERE SEVERAL DISCRE PANCIES WERE FOUND FOR WHICH GENUINENESS OF EXPENSES COULD NOT BE EXAM INED BY THE AO AND AN AMOUNT OF RS.1,86,600/- BEING 10% OF THE TOTAL E XPENSES WAS DISALLOWED AND ADDED BACK TO THE TOTAL INCOME OF TH E ASSESSEE. DURING THE APPELLATE PROCEEDINGS, THE REMAND REPORT WAS CA LLED FOR. IN THE REMAND REPORT THE AO OBSERVED THAT THE GENUINENESS OF THE TRANSACTION COULD NOT BE ASCERTAINED BY THE AO. IN THE ABSENC E OF THE VALID DOCUMENTS IN SUPPORT OF THE SAME THE AO FOUND THE POSSIBILITY OF BOGUS ENTRY. THE LEARNED CIT(A) IN THE APPELLATE PROCEEDI NGS OBSERVED THAT THE AO HAS NOT GIVEN ANY SPECIFIC FINDING ABOUT ANY BOG US CLAIM OF ANY SPECIFIC EXPENDITURE NEITHER MADE INQUIRY OR CROSS VERIFICATION OF THE RECIPIENTS TO ASCERTAIN THE GENUINENESS OF THE EXPE NDITURE AND CONSIDERING THE SAME THE LEARNED CIT(A) CONFIRMED AND RESTRICT ED TO A LUMP SUM DISALLOWANCE OF RS.1,00,000/-. 6. THE DEPARTMENTAL REPRESENTATIVE VEHEMENTLY ARGUE D IN SUPPORT OF THE ORDER PASSED BY THE AO AND THE ASSESSEE'S REPRE SENTATIVE HAS NOT MADE ANY REMARKABLE EFFORT TO CONTRADICT THE SAME. WE FIND THAT AO HAS NOT MADE ANY CROSS-VERIFICATION TO DISPROVE THE GEN UINENESS OF VARIOUS REPAIRS AND MAINTENANCE EXPENSES AND HE HAS MADE DI SALLOWANCE ON ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 6 - ESTIMATED BASIS FOR WANT OF PROPER BILLS AND VOUCHE RS. HOWEVER, THE LD.CIT(A) HAS RESTRICTED THE DISALLOWANCE TO RS.1,0 0,000/- ON THE BASIS OF SELF MADE VOUCHERS AS IT IS NOT POSSIBLE TO KEEP INVOICES/BILLS FOR EACH AND EVERY PETTY NATURE OF EXPENSES. WE THUS FIND D ECISION OF DISALLOWANCE OF RS.1,00,000/- MADE BY THE CIT(A) IS JUSTIFIED AND WE THEREFORE DO NOT FIND ANY FURTHER REASON TO INTERFE RE WITH THE ORDER PASSED BY THE LEARNED CIT(A). ACCORDINGLY, THE GROUND OF APPEAL PREFERRED BY THE REVENUE STANDS DISMISSED. 7. GROUND NO.3 RELATES TO ALLOWING THE EXPENSE S OF RS.16,25,011/- AS REVENUE EXPENDITURE INCURRED FOR THE SEAT REPAIRING OF NEWLY PURCHASED BUSES. 7.1. THE BRIEF FACTS RELATING TO THIS GROUND IS THIS THAT THE ASSESSEE HAS PURCHASED 52 CHASIS OF BUSES FROM THE COMPANIES DEA LING THEREIN AND INCURRED EXPENDITURE OF BODY FABRICATION THEREOF. THE ASSESSEE CLAIMED SEAT REPAIR EXPENSES OF RS.17,38,988/- AS IT APPEAR S FROM THE PROFIT & LOSS ACCOUNT. THE SEAT REPAIRING EXPENSES IN REGAR D TO THE NEW BUSES PURCHASED TO THE EXTENT OF RS.16,25,011/- HAS BEEN DISALLOWED BY THE AO ON FINDING IT CAPITAL EXPENDITURE AND ADDED BACK TO THE TOTAL INCOME OF THE ASSESSEE. THE LD.CIT(A) HAS DISPOSED OF THE AP PEAL BY DELETING THE ADDITION AND ALLOWED THE SAID REPAIRING EXPENSES AS REVENUE EXPENDITURE. ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 7 - 8. AT THE TIME OF HEARING OF THE MATTER, THE LD.DR STRONGLY ARGUED SUPPORTING THE CONTENTION MADE BY THE AO FOR DISALL OWANCE OF THE AMOUNT ON THE GROUND THAT SUCH EXPENSES IS CAPITAL IN NATURE. 8.1. ON THE OTHER HAND, REPRESENTATIVE OF THE ASSES SEE VEHEMENTLY ARGUED THAT SUCH EXPENDITURE IS A REVENUE ONE. HE FURTHER ADDED THAT REMODELING OF FURNITURE IN RETAIL OUTLET IS REVENUE EXPENDITURE AS IN THE CASE OF THE ASSESSEE. SUCH ISSUE HAS BEEN DECIDE D IN THE CASE OF C|IT VS. DELHI CLOTH AND GENERAL MILLS CO. LTD. (1981) 131 I TR 641 (DELHI) AS CITED BY THE LD.AR. 9. WE HAVE HEARD THE RIVAL SUBMISSIONS MADE BY THE REPRESENTATIVE OF THE PARTIES. WE HAVE PERUSED THE RELEVANT MATERIAL S AVAILABLE ON RECORD INCLUDING THE ORDER PASSED BY THE LD.AO, LD.CIT(A) AND THE REMAND REPORT AS WELL. THE LD.CIT(A) IN HIS ORDER IMPUGNE D IN THIS RESPECT OBSERVED AS FOLLOWS:- I HAVE CONSIDERED THE FACTS OF THE CASE, SUBMISSION MADE BY THE APPELLANT, REMAND REPORT FROM THE A.O, AND REJOINDE R TO THE REMAND REPORT. THE AO HAS MADE THE DISALLOWANCE OF RS.16,2 5,011/- TOWARDS THE SEAT REPAIRING EXPENSES TREATING THE SAME AS CAPITA L IN NATURE BY REJECTING THE APPELLANT'S CLAIM AS REVENUE EXPENDITURE. IT HA S BEEN OBSERVED BY THE A.O. THAT CERTAIN FIXED ASSETS IN THE FORM OF 52 CH ASIS OF BUSES HAVE BEEN PURCHASED BY THE APPELLANT. ON VERIFICATION OF THE LEDGER ACCOUNT OF SEAT ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 8 - REPAIRING EXPENSES AND THEIR BILLS THE AO WAS OF TH E VIEW THAT THE PURCHASES OF SEATS FOR NEW BUSES HAVE BEEN BOOKED B Y THE APPELLANT UNDER THE HEAD OF SEAT REPAIRING EXPENSES AND THOSE WERE CLAIMED AS REVENUE EXPENDITURE. ON THE OTHER SIDE, THE APPELLANT CONTENDED THAT THE ADDITION HAVE BEEN MADE BY THE AO WITHOUT ANY SHOW-CAUSE AND OPPO RTUNITY OF BEING HEARD. IT WAS CONTENDED THAT THE APPELLANT HAS INC URRED BODY BUILDING CHARGES OF THE NEW BUSES WHICH INCLUDED, THE NEW SE ATS FITTING EXPENSES IN THE NEWLY PURCHASED BUSES DURING THE YEAR UNDER CONSIDERATION AND ALL THESE BODY BUILDING CHARGES HAVE BEEN CAPITALIZED. THUS, NO EXPENDITURE OF THE SEAT FITTING OF THE NEW BUSES PURCHASED IN T HE YEAR UNDER CONSIDERATION HAVE BEEN DEBITED IN THE SEAT REPAIRI NG EXPENSES. IN FACT THE APPELLANT WAS INTO THE BUSINESS OF OPERATION OF CIT Y BUS SERVICE IN THE CITY OF BHAVNAGAR, BARODA, ANAND, NADIAD AND GANDHINAGAR . IN THE YEAR UNDER CONSIDERATION WITH APPROXIMATELY 175 OLD BUSE S EACH BUS CONTAINED ON AN AVERAGE SEAT RANGING FROM 32 TO 45 DEPENDING OF SIZE AND MODEL OF THE BUSES. FURTHER THE SEAT REPAIRING EXPE NSE WERE RELATING TO MATERIAL PURCHASED FOR REPAIRING OF SEATS IN THE OL D 175 BUSES AND WITH THE USE OF IN-HOUSE LABOUR THE REPAIRING OF SEATS W AS CARRIED OUT AS AND WHEN IT WAS REQUIRED. SINCE THE APPELLANT WAS ENGAG ED IN THE BUSINESS OF PUBLIC TRANSPORT AND HENCE THE DAMAGES OF THE SEATS WAS MUCH MORE THAN THE NORMAL ONE. ON AN AVERAGE RS.9,286/- PER BUS I N A YEAR EXPENDITURE ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 9 - MADE WAS VERY REASONABLE AND JUSTIFIED IN VIEW OF T HE PUBLIC TRANSPORTATION. FURTHER, IT WAS CONTENDED THAT THE EXPENDITURE IS INCURRED NOT ONLY ONCE FOR ALL AND NO NEW ASSET HAS CAME INT O THE EXISTENCE OR NO ADVANTAGE IN THE NATURE OF ENDURING BENEFIT IS DERI VED THEREFORE THE CAPITALIZATION OF THE AFORESAID EXPENDITURE WAS NOT WARRANTED. FURTHER, THE EXPENDITURE INCURRED WAS A PART OF THE NORMAL O PERATIONS OF THE BUSINESS AND HENCE THE SAME CANNOT BE HELD TO BE CA PITAL. FURTHER, IT WAS NOT A SUBSTANTIAL REPLACEMENT OF THE OLD SEATS AND THUS IT CANNOT BE SAID THAT IT WAS IN THE NATURE OF CAPITAL. IN SUPPORT, H E HAS RELIED UPON THE VARIOUS CASE LAWS AS REPRODUCED IN THE PRECEDING PA RAS OF THIS ORDER. ON VERIFICATION OF THE DETAILS OF THE EXPEN DITURE IT WAS SEEN THAT THE EXPENDITURES WERE REGULARLY MADE SINCE 26.5.2009 TO 15.3.2010 AND ALMOST IN EVERY MONTH THOSE HAVE BEEN INCURRED. HAD THE AFORESAID EXPENDITURES WERE PERTAINING TO THE NEWLY PURCHASED 52 BUSES ONLY IN THAT CASE THE ENTIRE EXPENDITURES WOULD HAVE BEEN C LAIMED BY ONE OR FEW MORE BILLS ON PARTICULAR DATES INSTEAD OF INCURRING THROUGH OUT THE YEAR. THE EXPENDITURES CLAIMED WERE IN SMALL AMOUNTS WHIC H ALSO DOES NOT ESTABLISH THAT THE SAME WERE RELATING TO THE NEW BU SES ONLY. THE AO HAS NOT BROUGHT ANYTHING ON RECORD TO ESTABLISH THAT TH OSE EXPENDITURES WERE INCURRED FOR THE NEW BUSES ONLY. ON THE OTHER SIDE THE ASSESSEE'S PLEA THAT IT HAS TO MAKE THE SEAT REPAIRING PERIODICALLY IN R ESPECT OF THE 175 OLD BUSES BEING USED IN ITS BUSINESS FOR PUBLIC TRANSPO RT. EVEN THE APPELLANT ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 10 - HAS NOT GRANTED ANY DEPRECIATION ON CAPITALIZATION OF THE EXPENSES AFTER CONSIDERING THE SAME AS CAPITAL EXPENDITURE WHICH A LSO SHOWS THAT THE AO HAS NOT APPRECIATED THE FACTS FULLY AND PROPERLY . IN VIEW OF THE AFORESAID DISCUSSION, THE CLAIM OF THE APPELLANT T REATING THE SAME AS NORMAL BUSINESS EXPENDITURES IS ALLOWABLE AS REVENU E EXPENDITURE U/S.37 OF THE I.T. ACT. UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE, WE F IND THAT NO ENDURING BENEFITS COULD BE DERIVED OUT OF THE EXPEN SES IN QUESTION MADE BY THE ASSESSEE. NEITHER ANY NEW ASSET HAS COME I NTO EXISTENCE NOR ANY SUBSTANTIAL REPLACEMENT OF THE OLD SEATS HAVE TAKEN PLACE. FOR MAINTENANCE OF THE 175 OLD BUSES, THE EXPENDITURES INCURRED COULD BE SAID TO BE REASONABLE AND NORMAL IN NATURE. FURTHER THAT THE EXPENSES CANNOT BE SAID TO BE BOG US SINCE THE GENUINENESS OF THE EXPENDITURE HAS NOT BEEN QUESTIO NED BY THE AO. 9.1. WE FIND NO DISCREPANCY IN THE ORDER PASSED BY THE LD.CIT(A) AND CONSEQUENTLY WE DO NOT JUSTIFY THE ORDER PASSED BY THE LD.AO IN ADDING THE INCOME AS CAPITAL EXPENDITURE. THE EXPENDITURE , IN OUR OPINION, IS REVENUE IN NATURE HAVING NO ENDURING BENEFIT. WE, THEREFORE, UPHOLD THE ORDER PASSED BY THE LD.CIT(A). THE GROUND OF APPE AL IS REJECTED. ITA NO.2713/AHD /2014 ACIT VS. VITCOS TRANSPORTATION P.LTD. ASST.YEAR 2010-11 - 11 - 10. IN THE RESULT, REVENUES APPEAL STANDS DISMISS ED. THIS ORDER PRONOUNCED IN OPEN COURT ON 16 / 0 5 /201 8 SD/- SD/- ( ) ( ) (AMARJIT SINGH) ( MS. MADHUMITA ROY ) ACCOUNTANT MEMBER JUDICIAL MEMBER AHMEDABAD; DATED 16/ 05 /2018 2,..*,.*../ T.C. NAIR, SR. PS !'#$#! / COPY OF THE ORDER FORWARDED TO : 1. #% / THE APPELLANT 2. &'#% / THE RESPONDENT. 3. 3 4 5 / CONCERNED CIT 4. 5 ( ) / THE CIT(A)-XX, AHMEDABAD-380 009 5. 89:&*4 , ,40 , 3 / DR, ITAT, AHMEDABAD 6. :;<=+ / GUARD FILE. / BY ORDER, '8& //TRUE COPY// / ( DY./ASSTT.REGISTRAR) , / ITAT, AHMEDABAD 1. DATE OF DICTATION .. 15.5.18(DICTATION-PAD - PAG ES ATTACHED AT THE END OF THIS APPEAL-FILE) 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 15.5.18 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.16.5.18 7. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 16.5.18 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