M/s. Shree Jalaram Industries, Ahmedabad V. The CIT., , Ahmedabad-III, Ahmedabad

ITA 352/AHD/2006

• Counselvise Citation: [2012] 140 COUNSELVISE.COM (IT) 60335 (ITAT-AHMEDABAD)
• Duration Of Justice: 6 year(s) 2 month(s) 28 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 11-05-2012
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Next Hearing Date: 28-03-2012
• Assessment Year: 2001-2002
• Appeal Filed On: 13-02-2006
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: B K
• Assessee Lawyers: A L THAKKAR
• Keywords: Document seized; Documents seized
• Section: 143(3); 133A; 147; 131; 263

Judgement Text

ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 1 IN THE INCOME TAX APPELLATE TRIBUNAL B BENCH, A HMEDABAD (BEFORE SHRI G.C.GUPTA VICE PRESIDENT & SHRI ANIL C HATURVEDI, A.M.) I.T.A. NO.352 /AHD/2006 (ASSESSMENT YEAR: 2001-02 ) I.T.A. NO.353/AHD/2006 (ASSESSMENT YEAR :2002-03 ) M/S.SHREE JALARAM INDUSTRIES 264, 265 GIDC HANSALPUR, VIRAMGAM, AHMEDABAD. (APPELLANT) VS. THE COMMISSIONER OF INCOME TAX, GUJARAT-III, AHMEDABAD. (RESPONDENT) PAN: AARFS0453Q APPELLANT BY : SHRI A.L. THAKKAR. RESPONDENT BY : SHRI B.K.S.PANDYA, SR. D.R. ( )/ ORDER DATE OF HEARING : 28-3-2012 DATE OF PRONOUNCEMENT :11-5-2012 PER: SHRI ANIL CHATURVEDI,A.M. THESE TWO APPEALS ARE FILED BY THE ASSESSEE AGAINST ORDER OF COMMISSIONER OF INCOME TAX, GUJARAT-III, AHMEDABAD DATED 5-1-2006 FOR THE ASSESSMENT YEARS 2001-02 AND 2002-03 RESPEC TIVELY. 2. THE ONLY EFFECTIVE GROUND TAKEN FOR BOTH THE YEA RS IS AS UNDER:- ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 2 THE LD. COMMISSIONER OF INCOME TAX, AHMEDABAD-III , HAS ERRED IN PASSING AN ORDER U/S. 263 OF THE INCOME TA X ACT,1961 WITHOUT ANY BASIS AND DIRECTING THE A.O. TO MAKE AS SESSMENT AFRESH, HENCE THE SAME IS ILLEGAL AND BAD IN LAW. 3. THE ASSESSEE FIRM IS DOING BUSINESS OF KAPAS, CO TTON SEEDS, COTTON BALES AND OIL JOB WORK BASIS. THE ASSESSEE FILED RETURN OF INCOME FOR A.Y. 2001-02 (ON 30-10-2001) & FOR AY 20 02-03 (ON 30-10- 2002) DECLARING TOTAL INCOME OF RS.43,196/- AND RS. NIL RESPECTIVELY. THE ASSESSMENT WAS COMPLETED U/S 143(3) FOR AY 2001 -02 ON 12-3- 2004 AND THE TOTAL INCOME WAS DETERMINED AT RS 71,6 90/-. THE ASSESSMENT FOR AY 2002-03 WAS COMPLETED ON 28-3-200 5 DETERMINING THE TOTAL INCOME AT RS.1,55,42,930/-. 4. SURVEY OPERATION U/S. 133A TOOK PLACE IN THE PRE MISES OF THE ASSESSEE ON 30-1-2002. DURING THE COURSE OF SURVEY OPERATION VARIOUS BOOKS OF ACCOUNT AND OTHER MATERIAL WAS FOUND. STAT EMENT U/S. 131 OF THE ACT WAS RECORDED OF SHRI THAKERSHI VADILAL, A P ARTNER AND THEREAFTER BOOKS OF ACCOUNTS WERE DULY IMPOUNDED. T HE BOOKS OF ACCOUNTS, DOCUMENTS AND OTHER MATERIAL PERTAINED TO THE ASSESSEE AS WELL AS ITS ASSOCIATE CONCERNS OPERATING IN THE GRO UP VIZ. SHRI SHAKTI COTTON PVT. LTD., UMA GINNING AND PROCESSING PVT. L TD., AND RAGHUVIR COTTON COMPANY. SUBSEQUENT TO THE SURVEY OPERATIONS U/S.133A THE ASSESSMENT WAS COMPLETED BY MAKING VARIOUS ADDITION S TO THE TOTAL INCOME. THE ASSESSMENT FOR AY 2002-03 WAS COMPLETED ON 28-3-2005 DETERMINING THE TOTAL INCOME AT RS.1,55,42,930/-. A GGRIEVED BY THE ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 3 ORDER OF THE AO, THE ASSESSEE FILED AN APPEAL BEFOR E THE CIT. CIT VIDE HIS ORDER DATED 12-6-2004 GRANTED PARTIAL RELIEF AG AINST THE VARIOUS ADDITIONS MADE. 5. ON 26.9.2005 LD. CIT AHMEDABAD-3 INITIATED PROCE EDINGS U/S. 263 FOR THE REASON THAT WHILE PASSING ASSESSMENT OR DER U/S. 143(3) FOR A.Y. 2001-02 AND 2002-03, THE A.O. HAD NOT VERIFIED THE TRANSACTIONS FROM THE BOOKS OF ACCOUNTS IMPOUNDED DURING THE COU RSE OF SURVEY. THE LD. CIT STATED THAT THE PARTICULARLY THE REGIST ER MARK X54 THAT WAS IMPOUNDED DURING THE COURSE OF SURVEY WAS NOT VERIF IED AND NOT CONSIDERED BY THE AO WHILE FRAMING THE ASSESSMENT F OR AY 2001-02 AND 2002-03 BECAUSE IT WAS FORWARDED ON 30.9.2002 T O I.T.O., WARD 8(3), AHMEDABAD. 6. IN RESPONSE TO THE NOTICE, THE ASSESSEE INTERALI A SUBMITTED THAT THE SOME OF THE IMPOUNDED REGISTER DOES NOT BELONG TO THE ASSESSEE, SOME OF THE REGISTERS CONTAINS DETAILS OF EXPENSES AND PAYMENTS AND WHICH ARE ALREADY RECORDED IN THE REGULAR BOOKS OF ACCOUNTS. WITH RESPECT TO THE REGISTER NO X-54 THAT WAS IMPOUNDE D, IT WAS SUBMITTED BY THE ASSESSEE THAT IT BELONGED TO ITS A SSOCIATE CONCERN NAMELY SHRI SHAKTI COTTON PVT LTD AND SHREE UMIYA G INNING PRESSING PVT LTD. AFTER ITS VERIFICATION, AND AFTER SATISFYI NG HIMSELF ABOUT THE CONTENTS OF THE REGISTER, THE AO INFORMED THE CONTE NTS OF THE REGISTER TO THE JURISDICTIONAL ASSESSING OFFICERS OF THE RES PECTIVE ASSOCIATE CONCERNS. THE CONCERNED ASSESSING OFFICERS OF THE A SSOCIATE CONCERNS TOOK NOTE OF THE CONTENTS AND CONSIDERED T HE SAME WHILE ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 4 FRAMING THE ASSESSMENT ORDERS. AS FAR AS THE CASE O F THE ASSESSEE WAS CONCERNED, BASED ON THE SEIZED DOCUMENTS, VARIO US ADDITIONS WERE MADE. IT WAS THUS SUBMITTED BY THE ASSESSEE TH AT IN VIEW OF THE GIVEN FACTS, THE ORDER OF THE AO CANNOT BE CONSIDER ED AS ERRONEOUS AND PREJUDICIAL TO THE INTEREST OF THE REVENUE AND THEREFORE THE CIT WAS REQUESTED TO DROP THE REVISIONARY PROCEEDINGS U /S 263. THE CIT DID NOT AGREE WITH THE CONTENTIONS OF THE ASSESSEE AND VIDE ORDER DATED 5.1.2006 SET ASIDE THE ASSESSMENT ORDERS FOR AY 2001-02 AND 2002-03 AND THE AO WAS DIRECTED TO MAKE FRESH ASSES SMENT. 7. AGGRIEVED BY THE ORDER OF CIT PASSED U/S 263 THE ASSESSEE IS IN APPEAL BEFORE US. 8. LD. A.R. ON BEHALF OF THE ASSESSEE STATED THAT T HE CIT HAD ERRED IN PASSING THE ORDER U/S 263 AND SETTING THE ASSESS MENT ASIDE. HE POINTED OUT THAT ONE OF THE REASON STATED BY CIT WA S THAT THE REGISTER REFERRED TO AS X 54 WHICH WAS IMPOUNDED DURING TH E COURSE OF SURVEY PROCEEDINGS WAS NOT AVAILABLE WITH THE A.O. AT THE TIME OF FINALIZING THE ASSESSMENT AND THEREFORE THE ASSESSM ENT IN THE CASE OF THE ASSESSEE HAS BEEN MADE WITHOUT CONSIDERING THE IMPORTANT FACTS AND EVIDENCE AVAILABLE IN REGISTER X-54 AND THERE FORE THE ASSESSMENT ORDER PASSED BY THE AO WAS ERRONEOUS AND PREJUDICIAL TO THE INTEREST OF THE REVENUE. THE FACT THAT THE X-5 4 REGISTER BELONGED TO THE ASSOCIATE CONCERNS WAS STATED BY SHRI THAKER SHI VADILAL THAKKAR IN A STATEMENT RECORDED U/S. 131 OF THE ACT , IMMEDIATELY SUBSEQUENT TO SURVEY OPERATIONS. IT WAS FURTHER STA TED THAT THE A.O. OF ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 5 THE ASSESSEE WHO HAD IMPOUNDED THESE REGISTERS HAD KEPT THEM IN HIS CUSTODY. THE A.O. OF THE ASSESSEE FIRM HAD EXAM INED THE PARTNER, VERIFIED HIS CONTENTIONS AND THEREAFTER CAME TO A C ONSCIOUS DECISION AND CONCLUDED THAT THE REGISTER X-54 BELONGED TO SHAKTI COTTON PVT. LTD., AND UMA GINNING AND PROCESSING LTD., THE ASSO CIATE CONCERNS. HE ACCORDINGLY FORWARDED COPY OF THE SURVEY REPORT ALONG WITH THESE IMPOUNDED REGISTERS AND DOCUMENTS TO THE JURISDICTI ONAL A.O. OF THE CONCERNED ASSOCIATE CONCERNS NAMELY SHAKTI COTTON P VT LTD AND UMA GINNING AND PROCESSING LTD. AFTER EXAMINATION OF TH E REGISTERS RECEIVED FROM THE AO OF THE ASSESSEE, CONSIDERING T HE DETAILED SUBMISSIONS MADE AND ON THE BASIS OF IMPOUNDED REGI STER MARKED X54, THE A.O. OF THE TWO ASSOCIATE CONCERNS HAD M ADE ADDITIONS IN THE HANDS OF THE ASSOCIATE CONCERNS. IT WAS THEREFO RE, NOT A CASE OF LACK OF INQUIRY BY THE A.O. WHICH HAS RESULTED INTO THE ORDER BEING TREATED AS ERRONEOUS. IT WAS FURTHER STATED VARIOUS INFORMATION THAT WAS CALLED FROM TIME TO TIME WAS FURNISHED DURING T HE COURSE OF ASSESSMENT PROCEEDINGS. THEREFORE, IT WAS VERY CLEA R THAT ALL THE INFORMATION WERE FURNISHED DURING THE COURSE OF ASS ESSMENT PROCEEDINGS U/S.142(1) OR SECTION 143(2), IT CANNOT BE THEREFORE BE SAID THAT THERE IS LACK OF INQUIRY OR BLIND ACCEPTA NCE OF THE RETURN FILED BY THE ASSESSEE ON THE PART OF THE A.O. IT WAS FURT HER STATED THAT IT CANNOT BE SAID THAT THERE WAS LACK OF INQUIRY OF TH E IMPOUNDED BOOKS ON THE PART OF THE AO AS THE REGISTERS WERE FORWARD ED BY HIM TO THE A.O. OF THE ASSOCIATE CONCERNS AFTER SATISFYING HIM SELF OF ITS CONTENTS AND THE AO OF THE ASSOCIATE CONCERNS IN TURN MADE A DDITIONS IN THE HANDS OF THE ASSOCIATE CONCERNS. THE ASSESSEE ALSO PLACED BEFORE US ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 6 THE ASSESSMENT ORDER DT. 19-11-2008 OF SHREE SHAKTI COTTON PVT. LTD., FOR ASSESSMENT YEAR 2002-03 PASSED U/S. 143(3) R.W. S. 147 OF THE ACT. WHILE PASSING THE ASSESSMENT ORDER, THE A.O. HAD CO NSIDERED REGISTER X57 WHICH WAS MAINTAINED BY JALARAM INDUSTRIES (ASS ESSEE). IN THIS ORDER, THE A.O. HAS MENTIONED THAT THE CONTENTION O F THE ASSESSEE IS CONSIDERED AND ENTRIES OF THE REGISTER MARKED X27 H AS BEEN EXAMINED AND VERIFIED WITH THE RECONCILIATION SUBMITTED BY T HE ASSESSEE VIS-- VIS THE BOOKS OF ACCOUNTS AND STATEMENT OF ACCOUNTS ALONG WITH RETURN OF INCOME FILED BY THE ASSESSEE. THE FIGURES APPEARING IN THE REGISTER MARKED X-27 WERE TALLIED WITH THE BOOKS OF ACCOUNT. IN VIEW OF THE AFORESAID FACTS THE LD. A.R. SUBMITTED THAT THE ACTION OF CIT BY RESORTING TO THE PROVISION OF SECTION 263 WAS NOT C ALLED FOR. 9. THE ASSESSEE RELIED ON THE FOLLOWING DECISIONS:- (1) CIT VS. SUN BEAM AUTO LTD., 227 CTR (DEL.) 133, (2) CIT VS. VIKAS POLYMERS (2010) 194 TAXMAN 57 (DE L); (3) VODAFONE ESSAR SOUTH LTD. VS. CIT (2011) 12 TAXMANN.COM.233; (4) NAGNATH HANUMANTRAO JALKOTE VS. ACIT(2008) 110 ITD 549 (PUNE). 10. THE LD. D.R. ON THE OTHER HAND CONTENDED THAT T HE SURVEY MATERIAL WAS NOT CONSIDERED WHILE FRAMING ASSESSMEN T ORDER U/S. 143(3) AND THEREFORE, IT WAS ERRONEOUS. HE FURTHER STATED THAT THERE WAS NO PROPER INQUIRY BY THE A.O. AND THEREFORE, OR DER WAS ERRONEOUS AND PREJUDICIAL TO THE INTEREST OF THE REVENUE. HE RELIED ON THE DECISION OF CIT VS. SESHASAYEE PAPER BOARDS LTD. (1 996) 217 ITR 358 ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 7 (MAD.); G.B. ENTERPRISE VS. ADDL. CIT (1975) 99 ITR 375 AND CIT VS. ARUNABEN SUMANKUMAR (2002) 124 TAXMAN- 57 (GUJ.) 11. WE HAVE HEARD THE RIVAL CONTENTIONS PERUSED THE MATERIAL ON RECORD PLACED BEFORE US. IT IS AN UNDISPUTED FACT T HAT SURVEY HAD TAKEN PLACE ON THE ASSESSEES PREMISES AND VARIOUS BOOKS OF ACCOUNTS, REGISTERS ETC., WERE IMPOUNDED. IT IS ALSO A FACT T HAT THE CONTENTS OF THE REGISTER X-54 BELONGED TO SHREE SHAKTI COTTON P VT. LTD., AND UMA GINNING AND PROCESSING PVT. LTD., AND NECESSARY CLA RIFICATION WAS GIVEN AT THE TIME OF SURVEY AS WELL AS DURING THE A SSESSMENT PROCEEDINGS. IT IS A FACT THAT AFTER EXAMINING THE CONTENTS OF REGISTER X-54 AND VERIFYING THE CONTENTION OF THE PARTNER OF THE ASSESSEE-FIRM AND APPLYING THE MIND TO THE FACTS OF THE CASE, THE A.O. FORWARDED THE DOCUMENTS AND REGISTER TO THE JURISDICTIONAL AOS O F THE ASSOCIATE COMPANIES. IT IS ALSO A FACT THAT WHILE FRAMING ASS ESSMENT OF SHREE SHAKTI COTTON PVT. LTD., THE A.O. WARD 8(3), AHMEDA BAD, HAD MADE ADDITIONS ON THE BASIS OF EXAMINATION OF REGISTER X-54 TO THE EXTENT OF RS. 23,66,301/-.THESE ADDITIONS WERE SUBSEQUENTLY D ELETED BY LD. CIT(A) BY HOLDING THAT THESE ADDITIONS WERE MADE ME RELY ON PRESUMPTIONS AND SURMISES. IT WAS NOT THE CASE WHER E NO INQUIRY WAS MADE BY THE AO WHICH HAS RESULTED INTO THE ORDER TO BE ERRONEOUS. THE A.O. HAS EXAMINED THE PARTNER, RECORDED THE STA TEMENT WHEREIN THE PARTNER HAD IDENTIFIED THE BOOKS AND ALSO STATE D TO WHOM IT BELONGED. IT WAS STATED BY HIM THAT THESE BOOKS BEL ONGED TO ASSOCIATE CONCERNS. ON THE BASIS OF STATEMENT AND A FTER VERIFYING THE BOOKS AND THE IMPOUNDED MATERIAL, THE A.O. CAME TO THE CONCLUSION ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 8 THAT THE IMPOUNDED REGISTER BELONGED TO THIRD PARTI ES. ACCORDINGLY, HE INTIMATED THE JURISDICTIONAL A.O. OF SUCH THIRD PAR TY AND HANDED OVER THE IMPOUNDED MATERIAL. HE ALSO MADE THE SURVEY REP ORT AVAILABLE TO THE A.O. OF THE THIRD PARTY. WHEN THE A.O. HAD EXER CISED THE OPTION OF SENDING THE IMPOUNDED MATERIAL OF THE ASSOCIATE CON CERNS TO THE CONCERNED A.OS, IT WAS WITH THE DEFINITE APPLICATIO N OF MIND. IT IS ALSO A FACT THAT BEFORE COMPLETING THE ASSESSMENT THE MA TERIAL FURNISHED TO A.O. WAS EXAMINED AND THEREAFTER CONSCIOUS DECISION WAS TAKEN BY HIM THAT THE CONTENTS OF THE IMPOUNDED REGISTER DOE S NOT BELONG TO THE ASSESSEE. 12. IN THE CASE OF CIT VS SUNBEAM AUTO LTD (SUPRA) IT HAS BEEN HELD BY HONBLE DELHI HIGH COURT THAT THERE IS DISTINCTI ON BETWEEN LACK OF ENQUIRY AND INADEQUATE INQUIRY. IF THERE IS AN E NQUIRY, EVEN INADEQUATE, THAT WOULD NOT BY ITSELF GIVE OCCASION TO THE CIT TO PASS ORDER U/S 263 MERELY BECAUSE HE HAS A DIFFERENT OPI NION IN THE MATTER. SUCH A COURSE OF ACTION IS OPEN ONLY IN CASES OF L ACK OF INQUIRY. 13. IN THE CASE OF CIT VS VIKAS POLYMERS (SUPRA) IT HAS HELD THAT THE POWER OF SUO MOTO REVISION BY THE COMMISSIONER IS S UPERVISORY IN NATURE. THE COMMISSIONER HAS TO BE SATISFIED OF TWI N CONDITIONS, NAMELY (I) THE ORDER OF THE AO SOUGHT TO BE REVISED IS ERRONEOUS; AND (II) IT IS PREJUDICIAL TO THE INTEREST OF THE REVEN UE. IF ONE OF THEM IS ABSENT - IF THE ORDER OF THE ITO IS ERRONEOUS BUT I S NOT PREJUDICIAL TO THE REVENUE OR IF IT IS NOT ERRONEOUS BUT IT IS PRE JUDICIAL TO THE REVENUE RECOURSE CANNOT BE HAD TO SECTION 263. ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 9 14. IN THE CASE OF CIT VS SESHASAYEE PAPER BOARDS L TD (SUPRA), THE FACTS WERE THAT THE ITO HAD ALLOWED RELIEF U/S 80J ON THE BASIS OF A HIGH COURT DECISION WHICH WAS REVERSED SUBSEQUENTLY BY SUPREME COURT. ON THOSE FACTS IT WAS HELD THAT THE ORDER PA SSED BY CIT U/S 263 WAS VALID BOTH IN RESPECT OF JURISDICTIONAL ASPECT AS WELL AS ON MERITS. 15. IN THE CASE OF GEE VEE ENTERPRISES VS ADDL CIT & ORS (SUPRA), IT WAS HELD THAT IT IS THE DUTY OF THE AO TO ASCERTAIN THE TRUTH OF THE FACTS STATED IN THE RETURN WHEN THE CIRCUMSTANCES OF THE CASE ARE SUCH AS TO PROVOKE AN INQUIRY. IF INQUIRY IS NOT MADE IN SU CH CASE THEN THE ORDER BECOMES ERRONEOUS. 16. IN THE CASE OF CIT VS. ARUNABEN SUMANKUMAR (SUP RA) WITH RESPECT TO THE SCOPE OF SECTION 263 IT WAS HELD THA T IT IS NOT NECESSARY THAT THE RECORD ON THE BASIS OF WHICH THE CIT CAN T AKE ACTION MUST BE THE RECORD OF THE CONCERNED ASSESSEE CIT HAS THE PO WER TO TAKE ACTION U/S 263 IN THE CASE OF AN ASSESSEE EVEN ON T HE BASIS OF THE RECORDS IN THE CASES OF OTHER PERSONS. 17. WE ARE OF THE VIEW THAT THE DECISIONS RELIED UP ON BY THE REVENUE ARE DISTINGUISHABLE ON THE FACTS AND ARE THEREFORE NOT APPLICABLE TO THE PRESENT CASE. IN VIEW OF FOREGOING FACTS AND VA RIOUS JUDICIAL DECISIONS, WE ARE OF THE CONSIDERED VIEW THAT THE O RDER PASSED BY THE AO WAS AFTER CONSIDERING THE MATERIAL ON RECORD AND THEREFORE CANNOT BE CONSIDERED AS ERRONEOUS AND PREJUDICIAL TO THE I NTEREST OF THE ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 10 REVENUE AS CONTEMPLATED UNDER SECTION 263. THUS BAS ED ON THE FOREGOING FACTS WE ARE OF THE CONSIDERED VIEW THAT THE ORDER OF CIT INITIATING THE PROCEEDINGS U/S 263 BE SET ASIDE. 18. WE THEREFORE, ALLOW THE APPEALS OF THE ASSESSEE . ORDER PRONOUNCED IN OPEN COURT ON 11 - 5 - 2012. SD/- SD/- (G.C.GUPTA) (ANIL CHATURVEDI) VICE PRESIDENT ACCOUNTANT MEMBER AHMEDABAD. S.A.PATKI. COPY OF THE ORDER FORWARDED TO: - 1. THE APPELLANT. 2. THE RESPONDENT. 3. THE CIT III, AHMEDABAD. 4. THE CIT CONCERNED. 5. THE DR., ITAT, AHMEDABAD. 6. GUARD FILE. BY ORDER DEPUTY/ASSTT.REGISTRAR ITAT,AHMEDABAD. ITA NO.3 52 & 353/AHD/2006 ASSESSME NT YEAR 2001-02 & 2002-03 . 11 1.DATE OF DICTATION 15 - 3 -2012 2.DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE TH E DICTATING 21 / 3 / 2012 MEMBER.OTHER MEMBER. 3.DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR. P.S./P.S - -2012. 4.DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE DICTATING MEMBER FOR PRONOUNCEMENT - -2012 5.DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR .P.S./P.S - -2012 6.DATE ON WHICH THE FILE GOES TO THE BENCH CLERK - -2012. 7.DATE ON WHICH THE FILE GOES TO THE HEAD CLERK . 8.THE DATE ON WHICH THE FILE GOES TO THE ASSTT. REG ISTRAR FOR SIGNATURE ON THE ORDER 9.DATE OF DESPATCH OF THE ORDER..