The Dy. Commissioner of Income Tax, Vijayawada V. Pidikiti Ranga Rao, Vijayawada

ITA 332/VIZ/2015

• Counselvise Citation: [2016] 130 COUNSELVISE.COM (IT) 9685 (ITAT-VISAKHAPATNAM)
• Duration Of Justice: 1 year(s) 3 month(s) 29 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-12-2016
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Assessment Year: 2012-2013
• Appeal Filed On: 10-08-2015
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: M K SETHI
• Keywords: Corroborative evidences; Revised return
• Section: 143(3); 133A; 131

Judgement Text

ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 1 , , IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM . , . , $ BEFORE SHRI V. DURGA RAO, JUDICIAL MEMBER & SHRI G. MANJUNATHA, ACCOUNTANT MEMBER ./I.T.A.NO.332 & 333/VIZAG/2015 ( / ASSESSMENT YEAR: 2012-13 & 2013-14) DCIT CIRCLE - 1(1), VIJAYAWADA VS. SRI PIDIKITI RANGA RAO, VIJAYAWADA [PAN: ACKPP6469Q ] ( % / APPELLANT) ( &'% / RESPONDENT) / APPELLANT BY : SHRI M.K. SETHI, DR / RESPONDENT BY : SHRI G.V .N. HARI, AR / DATE OF HEARING : 28.11.2016 / DATE OF PRONOUNCEMENT : 09.12.2016 / O R D E R PER G. MANJUNATHA, ACCOUNTANT MEMBER: THESE APPEALS FILED BY REVENUE ARE DIRECTED AGAINS T ORDER OF THE CIT(A), VIJAYAWADA DATED 12.6.2015 FOR THE ASSE SSMENT YEARS 2012-13 & 2013-14. SINCE, THE FACTS ARE IDENTICAL A ND ISSUES ARE ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 2 COMMON, THEY ARE CLUBBED, HEARD TOGETHER AND DISPOS ED-OFF BY WAY OF THIS COMMON ORDER FOR THE SAKE OF CONVENIENCE. 2. THE BRIEF FACTS OF THE CASE ARE THAT THE ASSESS EE IS A PROPRIETOR OF M/S. SWITCH GEARS AND FABRICATORS, FILED ITS ORIGIN AL RETURN OF INCOME FOR THE ASSESSMENT YEAR 2012-13 ON 27.9.2013 DECLARING TOTAL INCOME OF ` 7,95,310/-. THE ASSESSEE IS ALSO ONE OF THE DIRECT ORS OF M/S. USHA SPINCOAT PVT. LTD., GANNAVARAM AND MADE INVESTMENTS OF ` 2,05,50,000/- IN THE SHARE CAPITAL OF THE COMPANY. IN ORDER TO EXAMINE THE INVESTMENT MADE BY THE ASSESSEE, A SURVEY OPERA TION U/S 133A OF THE INCOME TAX ACT, 1961 (HEREINAFTER CALLED AS 'TH E ACT') WAS CONDUCTED ON 11.2.2014. DURING THE COURSE OF SURVEY, TWO SET S OF PROFIT & LOSS ACCOUNT FOR THE ASSESSMENT YEARS 2012-13 & 2013-14 HAVE BEEN NOTICED AND ALSO EXCESS STOCK VALUED ` 3,40,389/- WAS FOUND ON PHYSICAL INVENTORY. SUBSEQUENTLY, DURING THE COURSE OF POST SURVEY PROCEEDINGS, A SWORN STATEMENT WAS RECORDED U/S 131 OF THE ACT A ND THE ASSESSEE WAS ASKED TO EXPLAIN THE ABOVE DEFECTS. IN RESPONS E, THE ASSESSEE HAS ACCEPTED ADDITIONAL INCOME OF ` 1,30,00,000/- TO BE SPREAD OVER FOR ASSESSMENT YEARS 2012-13, 2013-14 & 2014-15. LATER ON, THE ASSESSEE HAS FILED A REVISED RETURN OF INCOME FOR THE ASSESS MENT YEAR 2012-13 ON 20.3.2014 DECLARING TOTAL INCOME OF ` 41,00,360/- INCLUDING ADDITIONAL INCOME OF ` 33,05,050/-, ADMITTED DURING THE COURSE OF SURVEY. THE ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 3 ASSESSMENT WAS COMPLETED U/S 143(3) R.W.S. 147 OF T HE ACT, ON 19.6.2014 ACCEPTING THE REVISED INCOME ADMITTED BY THE ASSESSEE. 3. DURING THE COURSE OF ASSESSMENT PROCEEDINGS, PEN ALTY PROCEEDINGS U/S 271(1)(C) OF THE AC,T WAS INITIATED CALLING FOR ASSESSEES EXPLANATIONS WHY PENALTY U/S 271(1)(C) OF THE ACT SHALL NOT BE L EVIED FOR CONCEALMENT OF PARTICULARS OF INCOME AND FURNISHING INACCURATE PARTICULARS OF INCOME. IN RESPONSE TO SHOW CAUSE NOTICE, THE ASSESSEE SUBM ITTED THAT DURING THE COURSE OF SURVEY, TWO SETS OF COMPUTERIZED TALL Y ACCOUNT WAS FOUND FOR ASSESSMENT YEAR 2012-13 WITH TWO DIFFERENT NET PROFITS. THE REASONS FOR MAINTAINING TWO SETS OF ACCOUNTS IS THAT DURING THE FINANCIAL YEAR, ONE ACCOUNTANT WHO WORKED UP TO JULY, 2012 HAS DONE ENTIRE ACCOUNTS HAS NOT UPDATED SOME OF THE ENTRIES IN RESPECT OF L AST 3 MONTHS EXPENDITURE AS WELL AS TRANSACTIONS PERTAINING TO B ANK LOANS. LATER ON, NEW ACCOUNTANT WAS JOINED AND COPIED THE ENTIRE ACC OUNTS AND MODIFIED WITH RESPECTIVE VOUCHERS AND GIVEN FOR AUDIT. AS S UCH, IN THE TRANSITION PERIOD, THE OLD ACCOUNT WAS NOT DELETED AND KEPT AS IT IS. HOWEVER, AT THE TIME OF AUDIT, THE BOOKS OF ACCOUNTS WERE UPDAT ED WITH NECESSARY ENTRIES WHICH WERE EXPLAINED TO THE ASSESSING OFFIC ER AT THE TIME OF ASSESSMENT. THE A.O. HAVING ENQUIRED ABOUT THE COR RECTNESS OF THE BOOKS OF ACCOUNTS HAS COMPLETED THE ASSESSMENT BY A CCEPTING INCOME ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 4 RETURNED. THEREFORE, THERE IS NO CONCEALMENT OF PA RTICULARS OF INCOME OR FURNISHING INACCURATE PARTICULARS OF INCOME. THE A .O. AFTER CONSIDERING THE EXPLANATIONS OF THE ASSESSEE HELD THAT BUT FOR THE SURVEY, THE ASSESSEE ADMITTED ADDITIONAL INCOME AND FILED REVIS ED RETURN OF INCOME, OTHERWISE THE NORMAL INCOME WAS ONLY ADMITTED. THO UGH, THERE IS NO ADDITION MADE DURING THE COURSE OF ASSESSMENT PROCE EDINGS, THE ASSESSEE FAILED TO EXPLAIN THE REASONS FOR NOT ADMI TTING TRUE AND CORRECT INCOME IN THE ORIGINAL RETURN OF INCOME FILED U/S 1 39(1) OF THE ACT, THEREFORE, HELD THAT THE ASSESSEE HAS CONCEALED PAR TICULARS OF INCOME WITHIN THE MEANING OF SECTION 271(1)(C) OF THE ACT AND ACCORDINGLY LEVIED PENALTY OF 100% TAX SOUGHT TO BE EVADED. 4. AGGRIEVED BY THE PENALTY ORDER, THE ASSESSEE PRE FERRED AN APPEAL BEFORE THE CIT(A). BEFORE THE CIT(A), THE ASSESSEE HAS FILED ELABORATE WRITTEN SUBMISSIONS AND CONTENDED THAT THERE IS NO CONCEALMENT OF PARTICULARS OF INCOME OR FURNISHING INACCURATE PART ICULARS OF INCOME, AS THE ASSESSEE HAS ADMITTED ADDITIONAL INCOME DURING THE COURSE OF SURVEY TO COVER UP THE DEFICIENCY POINTED OUT BY THE DEPAR TMENT AND FILED RETURN OF INCOME DISCLOSING ADDITIONAL INCOME ACCEP TED DURING THE COURSE OF SURVEY. THE ASSESSEE FURTHER SUBMITTED T HAT THE REASONS FOR MAINTENANCE OF TWO SETS OF ACCOUNTS HAS BEEN EXPLAI NED TO THE A.O. ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 5 WITH NECESSARY SUPPORTING EVIDENCE AND THE A.O. AFT ER EXAMINING THE DETAILS FILED BY THE ASSESSEE HAS CHOSEN TO ACCEPT THE RETURNED INCOME, THEREFORE, THERE IS NO REASON TO LEVY PENALTY FOR C ONCEALMENT OF INCOME OR FURNISHING INACCURATE PARTICULARS OF INCOME. TH E CIT(A) AFTER CONSIDERING THE EXPLANATIONS OF THE ASSESSEE HELD T HAT TWO SETS OF PROFIT & LOSS ACCOUNT FOUND DURING THE COURSE OF SURVEY OP ERATIONS SEEMS TO BE NOT UPDATED AT THE TIME OF SURVEY. THE CIT(A) F URTHER HELD THAT THE ASSESSEE HAS EXPLAINED THE DIFFERENCE OF ` 33,05,051/- NET PROFIT FROM 2 SETS OF PROFIT & LOSS ACCOUNTS WITH NECESSARY EVIDE NCES AND THE A.O. HAS EXAMINED THE DETAILS FILED BY THE ASSESSEE, HAS CHO SEN TO ACCEPT THE RETURN WITHOUT ANY FURTHER COMMENTS ON CONCEALMENT OF INCOME OR FURNISHING INACCURATE PARTICULARS OF INCOME. THE A SSESSEE HAS FILED REVISED RETURN OF INCOME DISCLOSING ADDITIONAL INCO ME AS PER STATEMENT GIVEN AT THE TIME OF SURVEY. ONCE THE REVISED RETU RN FILED WAS ACCEPTED BY THE A.O., THERE IS NO CONCEALMENT AS PER THE PRO VISIONS OF SECTION 271(1)(C) OF THE ACT. WITH THESE OBSERVATIONS, DELE TED PENALTY LEVIED BY THE A.O. FOR THE ASSESSMENT YEARS 2012-13 & 2013-14 . AGGRIEVED BY THE CIT(A) ORDER, THE REVENUE IS IN APPEAL BEFORE U S. 5. THE LD. D.R. SUBMITTED THAT THE LD. CIT(A) OUGHT TO HAVE UPHELD THE PENALTY LEVIED U/S 271(1)(C) OF THE ACT, AS THE ASSESSEE HAS ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 6 DELIBERATELY CONCEALED PARTICULARS OF INCOME AND EV ADED TAX BY NOT DISCLOSING TRUE INCOME IN HIS ORIGINAL RETURN OF IN COME FILED PRIOR TO CONDUCTING SURVEY OPERATION U/S 133A OF THE ACT. T HE D.R. FURTHER SUBMITTED THAT THE ASSESSEE HAS FAILED TO EXPLAIN T HE REASONS FOR MAINTAINING TWO SETS OF BOOKS OF ACCOUNTS WITH TWO DIFFERENT NET PROFITS. THOUGH, THE ASSESSEE TRIED TO EXPLAIN THAT THERE WA S A CHANGE OF ACCOUNTANT IN JULY, 2012 AND HENCE THERE WERE TWO S ETS OF ACCOUNTS, OUT OF WHICH, ONE WAS NOT UPDATED CANNOT BE ACCEPTABLE, AS AT THE TIME OF SURVEY OPERATION, THE FINANCIAL YEAR IS ALMOST CAME TO AN END. THE ASSESSEE HAS FILED REVISED RETURN ADMITTING ADDITIO NAL INCOME DISCLOSED DURING SURVEY BUT FOR THE REASON THAT THERE WAS A S URVEY OPERATION. UNLESS THE SURVEY TOOK PLACE, THE ASSESSEE WOULD NO T HAVE DISCLOSED TRUE AND CORRECT INCOME. THEREFORE, IT IS CLEAR CA SE OF DELIBERATE CONCEALMENT OF PARTICULARS OF INCOME AND HENCE THE A.O. HAS RIGHTLY LEVIED PENALTY U/S 271(1)(C) OF THE ACT. 6. THE LD. A.R. FOR THE ASSESSEE, ON THE OTHER HAND STRONGLY SUPPORTED ORDER OF THE CIT(A). THE A.R. FURTHER SU BMITTED THAT THE ASSESSEE HAS EXPLAINED THE REASONS FOR MAINTAINING TWO SETS OF ACCOUNTS WITH NECESSARY EVIDENCES. THE ASSESSEE ALSO RECONC ILED THE DIFFERENCE IN NET PROFIT FROM TWO SETS OF PROFIT & LOSS ACCOUN T BEFORE THE A.O. AND ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 7 THE A.O. HAS ACCEPTED THE EXPLANATIONS OF THE ASSES SEE, THEREFORE, THERE IS NO REASON TO LEVY PENALTY FOR CONCEALMENT OF INC OME U/S 271(1)(C) OF THE ACT. THE A.R. FURTHER SUBMITTED THAT THE ADDIT IONAL INCOME DISCLOSED DURING THE COURSE OF SURVEY IS NOT BASED ON ANY DOC UMENTS WHICH SUGGEST THE CONCEALMENT OF INCOME. THE ASSESSEE HA S ADMITTED ADDITIONAL INCOME TO COVER UP THE DEFICIENCIES AND ALSO TO BUY PEACE FROM THE DEPARTMENT. ONCE REVISED RETURN OF INCOME FILED ACCEPTING ADDITIONAL INCOME DISCLOSED DURING THE COURSE OF SU RVEY, THERE IS NO REASON FOR THE A.O. TO INFER THAT THE ASSESSEE HAS DELIBERATELY CONCEALED PARTICULARS OF INCOME OR FURNISHED INACCURATE PARTI CULARS OF INCOME TO LEVY PENALTY U/S 271(1)(C) OF THE ACT. IN SUPPORT OF HIS ARGUMENTS, RELIED UPON THE DECISION OF HONBLE SUPREME COURT, IN THE CASE OF CIT VS. SURESH CHANDRA MITTAL 251 ITR 9 AND HONBLE DEL HI HIGH COURT DECISION IN THE CASE OF CIT VS. SAS PHARMACEUTICALS LTD. 7. WE HAVE HEARD BOTH THE PARTIES, PERUSED THE MATER IALS AVAILABLE ON RECORD AND GONE THROUGH THE ORDERS OF THE AUTHOR ITIES BELOW. THE A.O. LEVIED PENALTY U/S 271(1)(C) OF THE ACT, FOR T HE REASON THAT THE ASSESSEE HAS DELIBERATELY CONCEALED PARTICULARS OF INCOME BY NOT DISCLOSING TRUE AND CORRECT INCOME IN THE ORIGINAL RETURN OF INCOME FILED U/S 139(1) OF THE ACT. THOUGH, THE ASSESSEE HAS DI SCLOSED ADDITIONAL ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 8 INCOME BY FILING REVISED RETURN OF INCOME, BUT FOR THE SURVEY ASSESSEE HAS DISCLOSED ADDITIONAL INCOME, OTHERWISE, THE ASS ESSEE WOULD NOT HAVE DISCLOSED TRUE AND CORRECT INCOME. THE A.O. HAS CL EARLY BROUGHT OUT FACTS TO STATE THAT THE ASSESSEE HAS MAINTAINED TWO SETS OF BOOKS OF ACCOUNTS WHICH IS A CLEAR CASE OF CONCEALMENT OF PA RTICULARS OF INCOME. IT IS THE CONTENTION OF THE ASSESSEE THAT IT HAS EX PLAINED THE REASONS FOR MAINTAINING TWO SETS OF BOOKS OF ACCOUNTS. ACCORDI NG TO THE ASSESSEE, THE ACCOUNTANT WHO MAINTAINED THE BOOKS OF ACCOUNTS HAS LEFT IN BETWEEN AND THE NEW ACCOUNTANT WHO HAS TAKEN UP THE JOB HAS COPIED THE PREVIOUS DATA OF BOOKS OF ACCOUNTS AND MODIFIED WITH NECESSARY ENTRIES TO COMPLETE THE BOOKS OF ACCOUNTS. THE BOO KS OF ACCOUNTS WERE AUDITED AS PER THE PROVISIONS OF SECTION 44AB OF TH E ACT. THE A.O. DURING THE COURSE OF ASSESSMENT PROCEEDINGS HAS ACC EPTED THE BOOKS OF ACCOUNTS WITHOUT ANY OBSERVATIONS AS TO DISCREPANCI ES IN THE BOOKS OF ACCOUNTS. THEREFORE, IT IS NOT CORRECT TO STATE TH AT THE ASSESSEE HAS CONCEALED PARTICULARS OF INCOME WHICH WARRANTS LEVY OF PENALTY U/S 271(1)(C) OF THE ACT. 8. HAVING HEARD BOTH THE SIDES, WE FIND THAT DURING THE COURSE OF SURVEY OPERATION, THE ASSESSEE HAS ADMITTED ADDITIO NAL INCOME AND FILED REVISED RETURN OF INCOME ADMITTING INCOME DISCLOSED DURING THE COURSE ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 9 OF SURVEY OPERATION. THE A.O. COMPLETED THE ASSESS MENT ACCEPTING THE RETURN OF INCOME FILED BY THE ASSESSEE WITHOUT ANY ADDITIONS. WE FURTHER NOTICED THAT THE ASSESSEE HAS EXPLAINED THE REASONS FOR MAINTAINING TWO SETS OF BOOKS OF ACCOUNTS. THE ASS ESSEE ALSO RECONCILED THE DIFFERENCE OF NET PROFIT FROM TWO SETS OF PROFI T & LOSS ACCOUNT BY EXPLAINING THAT ONE SET OF PROFIT & LOSS ACCOUNT FO UND DURING THE COURSE OF SURVEY WAS INCOMPLETE WHICH WAS NOT UPDATED AT T HE TIME OF SURVEY. THE CIT(A) AFTER CONSIDERING THE RELEVANT DETAILS H AS RECORDED CLEAR FINDINGS OF FACT THAT THE ASSESSEE HAS RECONCILED T HE DIFFERENCE OF ` 33,05,051/- PROFIT FROM TWO SETS OF PROFIT & LOSS A CCOUNT IN AS MUCH THE PURCHASES AND OTHER EXPENDITURE FOR THE MONTH OF JA NUARY, FEBRUARY & MARCH, 2012 HAVE NOT BEEN ACCOUNTED AT THE TIME OF SURVEY, WHICH WAS FURTHER SUPPORTED BY DOCUMENTARY EVIDENCES. THE A. O. AFTER SATISFIED WITH THE CORRECTNESS OF THE BOOKS OF ACCOUNTS HAS A CCEPTED THE RETURN OF INCOME FILED BY THE ASSESSEE WITHOUT FURTHER COMMEN T ON CONCEALMENT OF PARTICULARS OF INCOME. THEREFORE, WE ARE OF THE VIEW THAT ONCE REVISED RETURN OF INCOME FILED ACCEPTING INCOME DIS CLOSED DURING THE COURSE OF SURVEY OPERATION WITH A REQUEST TO IMMUNI TY FROM THE PENALTY PROCEEDINGS, THE A.O. WAS INCORRECT IN LEVYING PENA LTY U/S 271(1)(C) OF THE ACT. ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 10 9. THE ASSESSEE RELIED UPON THE DECISION OF THE HON BLE SUPREME COURT, IN THE CASE OF CIT VS. SURESH CHANDRA MITTAL 251 ITR 9, WHEREIN THE COURT, OBSERVED THAT IF THE ASSESSEE HAS OFFERE D ADDITIONAL INCOME TO BUY PEACE OF MIND TO AVOID LITIGATION, PENALTY U/S 271(1)(C) OF THE ACT CANNOT BE LEVIED. SIMILARLY, THE HONBLE HIGH COUR T OF DELHI IN THE CASE OF CIT VS. SAS PHARMACEUTICALS LTD. HELD THAT THOUG H IT IS POSSIBLE THAT BUT FOR DETECTION IN THE SURVEY, THE ASSESSEE MIGHT NOT HAVE OFFERED THE INCOME, THE PENALTY U/S 271(1)(C) OF THE ACT CAN ON LY BE LEVIED IF IN THE COURSE OF PROCEEDINGS THE A.O. IS SATISFIED THAT TH ERE IS CONCEALMENT OR FURNISHING OF INACCURATE PARTICULARS. THE WORDS IN THE COURSE OF PROCEEDINGS MEAN THE ASSESSMENT PROCEEDINGS BECAUSE THERE IS NO QUESTION OF SATISFACTION OF THE A.O. IN SURVEY PROC EEDINGS. FURTHER, THE QUESTION WHETHER THERE IS CONCEALMENT OR INACCURATE PARTICULARS HAS TO BE DETERMINED WITH REFERENCE TO THE RETURN OF INCOM E. IN THE PRESENT CASE ON HAND, THE ASSESSEE HAS FILED REVISED RETURN OF INCOME ADMITTING ADDITIONAL INCOME DISCLOSED DURING THE COURSE OF SU RVEY AND THE A.O. HAS COMPLETED ASSESSMENT BY ACCEPTING INCOME RETURNED B Y THE ASSESSEE. THEREFORE, WE ARE OF THE VIEW THAT THERE IS NO CONC EALMENT OF PARTICULARS OF INCOME OR FURNISHING INACCURATE PARTICULARS OF I NCOME, WHICH WARRANTS LEVY OF PENALTY U/S 271(1)(C) OF THE ACT. THE CIT( A) AFTER CONSIDERING RELEVANT FACTS HAS RIGHTLY DELETED PENALTY LEVIED B Y THE A.O. WE DO NOT ITA NO.332/VIZAG/2015 SRI PIDIKITI RANGA RAO, VIJAYAWADA 11 SEE ANY REASONS TO INTERFERE WITH THE ORDER OF LD. CIT(A). HENCE, WE INCLINED TO UPHOLD THE CIT(A) ORDER AND DISMISS THE APPEALS FILED BY THE REVENUE FOR THE ASSESSMENT YEARS 2012-13 & 2013-14. 10. IN THE RESULT, THE APPEALS FILED BY THE REVENUE ARE DISMISSED. THE ABOVE ORDER WAS PRONOUNCED IN THE OPEN COURT ON 9 TH DEC16. SD/- SD/- ( . ) ( . ) (V. DURGA RAO) (G. MANJUNATHA) /JUDICIAL MEMBER /ACCOUNTANT MEMBER # /VISAKHAPATNAM: ' /DATED : 9.12.2016 VG/SPS )# *# /COPY OF THE ORDER FORWARDED TO:- 1. / THE APPELLANT THE DCIT, CIRCLE-1(1), VIJAYAWAD A 2. / THE RESPONDENT SRI PIDIKITI RANGA RAO, PROP: M /S. SWITCH GEARS & FABRICATORS, ENIKEPADU, VIJAYAWADA. 3. + / THE CIT, VIJAYAWADA 4. + ( ) / THE CIT (A), VIJAYAWADA 5. # . , . , # / DR, ITAT, VISAKHAPATNAM 6 . / GUARD FILE / BY ORDER // TRUE COPY // 12 . (SR.PRIVATE SECRETARY) . , # / ITAT, VISAKHAPATNAM SL. NO. DESCRIPTION DATE INITIALS 1. DATE OF DICTATION BY THE AUTHOR 28.11.2016 SR.P S 2. DRAFT PLACED BEFORE THE DICTATING MEMBER 29.11.2 016 SR.PS 3. DRAFT PLACED BEFORE THE SECOND MEMBER SR. PS 4. DRAFT APPROVED BY THE SECOND MEMBER SR. PS 5. DATE OF APPROVED ORDER COMES TO THE SR. PS SR. PS 6. DATE OF PRONOUNCEMENT OF ORDER SR. PS 7. DATE OF FILE SENT TO THE BENCH CLERK SR. PS 8. DATE ON WHICH FILE GOES TO THE HEAD CLERK HD. C LK 9. DATE OF DISPATCH OF ORDER SR. PS