DCIT, New Delhi V. M/s Hind Industries Ltd., New Delhi

ITA 3535/DEL/2016

• Counselvise Citation: [2020] 111 COUNSELVISE.COM (IT) 2392 (ITAT-DELHI)
• Duration Of Justice: 3 year(s) 9 month(s) 2 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-03-2020
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: G
• Assessment Year: 2011-2012
• Appeal Filed On: 15-06-2016
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: H K CHAUDHARY
• Keywords: Bogus purchase; Earning of tax free income; Permanent establishment; Rule 8D
• Section: 69C; 40A(3); 14A; 133(6); 195; 250; 274; 72; 13; 22

Judgement Text

1 ITA NO. 3535/DEL/2016 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: G NEW DELHI BEFORE SHRI N. K. BILLAIYA, ACCOUNTANT ME MBER AND MS SUCHITRA KAMBLE, JUDIC IAL MEMBER ITA NO. 3535/DEL/2016 ( A .Y 2011-12) DCIT CIRCLE 11(1) NEW DELHI (APPELLANT) VS HIND INDUSTRIES LTD. A-1, PHASE-1, OKHLA INDUSTRIAL AREA NEW DELHI AAACH0870N (RESPONDENT) APPELLANT BY SH. H. K. CHAUDHARY, CIT DR RESPONDENT BY SH. M. P. RASTOGI, ADV ORDER PER SUCHITRA KAMBLE, JM THIS APPEAL IS FILED BY THE REVENUE AGAINST THE ORD ER DATED 04/03/2016 PASSED BY CIT(A)-16, NEW DELHI FOR ASSESSMENT YEAR 2011-12. 2. THE GROUNDS OF APPEAL ARE AS UNDER:- 1. WHETHER ON THE FACTS AND THE CIRCUMSTANCES OF T HE CASE, LD.CIT(A) WAS CORRECT IN DELETING THE DISALLOWANCE OF RS. 1,64,54 ,752/- MADE ON ACCOUNT U/S 14A R.W.R 8D? 2. WHETHER ON THE FACTS AND THE CIRCUMSTANCES OF THE C ASE, LD.CIT(A) WAS CORRECT IN DELETING THE ADDITION OF RS. 79,13,46,36 9/- U/S 69C OF THE I.T ACT, 1961 IGNORING THE FACT THAT THE PURCHASES WERE NOT GENUINE AND ALL THE NOTICES U/S 133(6) ISSUED TO PARTIES WERE RETURNED UNDELIVE RED.? DATE OF HEARING 19.02.2020 DATE OF PRONOUNCEMENT 18 .03.2020 2 ITA NO. 3535/DEL/2016 3. THE ASSESSEE IS ENGAGED IN THE BUSINESS OF MARKE TING OF MANUFACTURED FERTILIZERS AND RETAILED INTERMEDIATE PRODUCTS AS W ELL AS EXPORT OF FROZEN AND FRESH MEAT. ASSESSEE FILED ITS RETURN OF INCOME ON 29.09.2011 DECLARING AN INCOME OF RS. 4,93,25,680/-. THE ASSESSING OFFICER MADE DISALLOWANCE OF COMMISSION TO MANAGING DIRECTOR TO THE EXTENT OF RS . 2,81,405/-. THE ASSESSING OFFICER FURTHER MADE DISALLOWANCE OF RS. 79,13,46,369/- ON ACCOUNT OF UNVERIFIABLE & UNEXPLAINED CASH PURCHASES UNDER SECTION 69C OF THE INCOME TAX ACT, 1961. THE ASSESSING OFFICER ALSO MADE DISA LLOWANCE OF RS. 1,64,54,752/- TOWARDS APPLICABILITY OF SECTION 14A READ WITH RULE 8D. 4. BEING AGGRIEVED BY THE ASSESSMENT ORDER, THE ASS ESSEE FILED APPEAL BEFORE THE CIT (A). THE CIT (A) ALLOWED THE APPEAL OF THE ASSESSEE. 5. AS REGARDS TO GROUND NO. 1, THE LD. DR SUBMITTED THAT THE ASSESSING OFFICER HAS RIGHTLY MADE DISALLOWANCE OF RS. 164,54 ,752/- TOWARDS APPLICABILITY OF SECTION 14A READ WITH RULE 8D. AS REGARDS TO GRO UND NO. 2, THE LD. DR SUBMITTED THAT AS MENTIONED BY THE ASSESSING OFFICE R IN PARA 4, PURCHASES OF RS.79,13,46,369 WERE FOUND TO BE NOT SUPPORTED BY A NY VOUCHERS, CHALLAN OR DOCUMENTARY EVIDENCE. THE LD. DR SUBMITTED THAT NOT ICES U/S 133(6) WAS ISSUED TO ALL THE 26 PARTIES AND IN ALL THE CASES, NOTICES U/S 133(6) WERE RETURNED BACK WITH POSTAL REMARKS NO SUCH PERSON IS AVAILABLE AT THE GIVEN ADDRESSES. THE ASSESSEE WAS DULY CONFRONTED WITH TH E ABOVE FACTS. THEREAFTER, SOME DETAILS WERE FILED BY THE ASSESSEE. IT WAS OBS ERVED BY THE ASSESSING OFFICER THAT THERE WAS DIFFERENCE IN SIGNATURES ON THE PAYMENT SLIP AND LETTERS FILED BY THE ASSESSEE. THESE DIFFERENCES ARE HIGHLI GHTED ON PAGES 7 & 8 OF THE ASSESSMENT ORDER. THUS, ADDITIONS U/S 69C OF RS.79, 13,46,369 WAS MADE ON ACCOUNT OF BOGUS PURCHASES. THE LD. DR FURTHER SUBM ITTED THAT IN EARLIER YEARS, DISALLOWANCES WAS MADE U/S 40A(3). THUS THE CIT(A) HAS INCORRECTLY DELETED THE ADDITION RELYING UPON PAST HISTORY OF T HE ASSESSEE. THE LD. DR RELIED UPON THE FOLLOWING DECISIONS: N. K. PROTEINS LTD. VS. CIT(A) (2017-TIOL-23-SC-IT) 3 ITA NO. 3535/DEL/2016 N. K. PROTEINS LTD. VS. CIT( 2016-TIOL-3166-H.C-AHM -IT) CIT(A) VS. ARUN MALHOTRA 47 TAXMANN.COM 385 (DELHI) 2014 363 ITR 195 VIJAY PROTEINS LTD. VS. ACIT [2015] 58 TAXMANN.COM 44 (GUJRAT) CIT(A) VS. MEDICA [2001] 117 TAXMAN 628 (DELHI)/[20 01] 250 ITR 575 (DELHI)/[2001] 168 CTR 314 (DELHI) PREM CASTINGS (P) LTD. VS. CIT(A) [2017] 88 TAXMANN .COM 189 (ALLAHABAD) PREM CASTINGS (P) LTD. VS. CIT2018-TIOL-274-S.C-IT KONARK STRUCTURAL ENGINEERING (P) LTD. VS. DCIT [2 018] 90 TAXMANN.COM 56 (BOMBAY) PCIT VS.BIRKAM SINGH [ ITA NO. 55/2017] (DELHI) SANJAY OLICAKE INDUSTRIES VS. CIT(A) [ 2009] 316 IT R 274 (GUJRAT) N. K. INDUSTRIES LTD. VS. DCIT [2016] 72 TAXMANN. C OM 289 (GUJRAT)/[2017] 292 CTR 354 (GUJARAT) 6. AS REGARDS TO GROUND NO. 1, THE LD. AR SUBMITTED THAT THE ASSESSEE HAS NOT RECEIVED ANY EXEMPT INCOME DURING THE YEAR UNDE R CONSIDERATION. AS REGARDS TO GROUND NO. 2, THE LD. AR SUBMITTED THAT ALL THE EXPORT RECEIPTS ARE CREDITED IN THE BANK ACCOUNTS WHEREFROM THE WITHDRA WALS WERE MADE FOR THE DISBURSEMENT OF PURCHASE AND OTHER EXPENSES. DURING THE YEAR UNDER CONSIDERATION, THE SALES WERE TO THE TUNE OF RS. 13 8 CRORE IN COMPARISON TO RS.122 CRORE IN PRECEDING YEAR. DURING THE YEAR UND ER CONSIDERATION, THE PURCHASES WERE AMOUNTING TO RS. 109 CRORE, OUT OF W HICH THE PURCHASES AMOUNTING TO RS.79.13 CRORES WERE MADE IN CASH FROM FARMERS AND GROWERS OF ANIMALS. IN THE TRADE OF MEAT, THE GROWERS/PRODUCER S FROM WHOM THE RESPONDENT-ASSESSEE USED TO PURCHASE WERE ILLITERAT E HAVING NO PERMANENT RESIDENCE AND DO NOT MAINTAIN BANK ACCOUNT. THE LD. AR SUBMITTED THAT BASICALLY THEY OPERATE IN A GROUP UNDER THE NAME OF AN INDIVIDUAL WHO HEADS THE TEAM AND INTERACTS WITH THE ASSESSEE ON BEHALF OF HIMSELF AND OTHER 4 ITA NO. 3535/DEL/2016 PERSONS IN THE GROUP. TILL PRECEDING YEAR, THE ASSE SSING OFFICER DISALLOWED THE PAYMENTS AGAINST PURCHASES U/S 40A(3) OF IT ACT. HO WEVER ON APPEAL, THE TRIBUNAL DELETED THE DISALLOWANCE MADE BY THE ASSES SING OFFICER ON ACCOUNT OF CASH PURCHASES AFTER FOLLOWING RULE 6DD OF IT RULES FOR ASSESSMENT YEAR 2003- 04 TO 2009-10. APPEAL FOR ASSESSMENT YEAR 2010-11 I S PENDING BEFORE THE TRIBUNAL. HOWEVER, FOR THE FIRST TIME IN ASSESSMENT YEAR 2011-12, THE ASSESSING OFFICER HAS OBSERVED AT PAGE 9 OF THE ASS ESSMENT ORDER THAT THE CASH PURCHASES OF THE ASSESSEE ARE NOT VERIFIABLE AND TH EN TREATED THE WHOLE OF THE CASH PURCHASES AS BOGUS AND THEN MADE THE ADDITION OF THE CORRESPONDING AMOUNT OF UNVERIFIABLE CASH PURCHASES AS UNEXPLAINE D EXPENDITURE IN TERMS OF SECTION 69C OF IT ACT. THE CIT (APPEALS) AFTER NOTI CING THE PAST HISTORY OF THE CASE WHEREIN THE DISALLOWANCES WERE MADE AGAINST TH E CASH PURCHASE U/S 40A(3) OF IT ACT, WHICH WERE SUBSEQUENTLY DELETED B Y TRIBUNAL, THE LEARNED CIT OBSERVED THAT IN EARLIER YEARS THE ASSESSING OFFICE R USED TO DISALLOW THE PURCHASES TO THE EXTENT OF 20% OF THE TOTAL PURCHAS ES ON ACCOUNT OF CASH PAYMENT IN VIOLATION OF SECTION 40A(3) OF IT ACT, B UT THIS YEAR THE ASSESSING OFFICER INSTEAD OF APPLYING THE PROVISION OF SECTIO N 40A(3) HAS INVOKED THE PROVISIONS OF SECTION 69C OF IT ACT WHICH IMPLIES T HAT THE ASSESSING OFFICER IS NOT SATISFIED WITH THE SOURCE OF INVESTMENT IN PURC HASES. THE CIT (APPEALS) THEREAFTER OBSERVED THAT THERE ARE TWO ISSUES: (I) THE INVESTMENT IN PURCHASE NOT EXPENDITURE, OR (II) THE PARTIES FROM WHOM THE PURCHASES ARE MADE A RE NOT GENUINE. THE LD. AR SUBMITTED THAT THE CIT (APPEALS) OBSERVE D THAT FROM THE ASSESSMENT ORDER IT APPEARS THAT THE ASSESSING OFFI CER HAS MIXED UP TWO ISSUES IN ONE AND HIS FINDINGS AND HIS CONCLUSIONS ARE NOT RELATED. WHILE MAKING THE DISALLOWANCE, THE ASSESSING OFFICER HAS LAID MUCH STRESS ON THE NON-VERIFICATION OF PARTIES FROM WHOM PURCHASES HAV E BEEN MADE. THEREAFTER AFTER FOLLOWING THE TRIBUNAL MUMBAI BENCH ORDER IN THE CASE OF EAGLE IMPEX IN 5 ITA NO. 3535/DEL/2016 ITA NO. 5697/MUM/2010 DATED 22 ND FEBRUARY 2013, WHEREIN THE TRIBUNAL, AFTER CONSIDERING THE FACT THAT WHEN THE SALES/EXPO RTS ARE ACCEPTED BY THE ASSESSING OFFICER AND THE ASSESSEE HAS DISCLOSED TH E QUANTITATIVE TALLY ALSO, IT MEANS THAT THE ASSESSEE MUST HAVE MADE PURCHASES AL SO, FOR WHICH THERE IS CORRESPONDING SALES AND ONCE THE SALES HAVE BEEN AC CEPTED BY THE ASSESSING OFFICER, THEN IT WOULD BE FARFETCHED TO PERCEIVE TH AT SUCH A HUGE QUANTITY OF PURCHASES HAS NOT BEEN MADE, HAS DELETED THE PURCHA SES AMOUNTING TO RS.79.13 CRORE. THE LD. AR SUBMITTED THAT BEFORE TH E ASSESSING OFFICER, THE ASSESSEE HAS FURNISHED FROM THE PROFIT & LOSS ACCOU NT AND BALANCE SHEET AND AUDITORS REPORT ALONG WITH TAX AUDIT REPORT WHICH INCLUDES THE QUANTITATIVE TALLY OF THE PURCHASES OF MEAT AND EXPORTS THEREOF. THE SALES WHICH ARE FROM EXPORTS HAVE BEEN ACCEPTED BY THE ASSESSING OFFICER . SUCH SALES HAVE BEEN CREDITED IN THE BANK ACCOUNTS WHEREFROM THE WITHDRA WALS HAVE BEEN MADE FOR THE PAYMENT OF PURCHASE AND OTHER EXPENSES. IT IS N OT THE CASE OF THE ASSESSING OFFICER THAT NO SALES HAVE BEEN MADE BY THE RESPOND ENT-ASSESSEE. IT IS NOT THE CASE OF THE ASSESSING OFFICER THAT THE PAYMENTS AGA INST THE PURCHASES HAVE BEEN MADE BY THE ASSESSEE OUT OF THE BOOKS OF ACCOU NT AND NOT SHOWN IN THE BOOKS OF ACCOUNT BECAUSE IT IS ONLY OUT OF THE TOTA L PURCHASES CLAIMED BY THE ASSESSEE, AN AMOUNT OF RS.79.13 HAS BEEN DISALLOWED . THE PROVISION OF SECTION 69C OF IT ACT IS A DISCRETIONARY PROVISION AND NOT MANDATORY PROVISION. THE LD. AR RELIED UPON THE FOLLOWING DECISIONS: I) PR. CIT VS. RAMA SHANKAR YADAV (2017) 85 TAXMANN.CO M 173 (ALL) II) CIT VS. SMT. PK NOORJAHAN 123 ITR 3 (KERALA) III) CIT VS. SMT. PK NOORJAHAN 237 ITR 570 (SC) THE LD. AR SUBMITTED THAT IF THE ASSESSEE EXPLAINS THE SOURCE OF PAYMENT AND THERE IS NO DISPUTE ABOUT THE SOURCE OF PAYMENT, TH EN SECTION 69C OF IT ACT IS NOT APPLICABLE. THE LD. AR RELIED UPON THE FOLLOWIN G DECISIONS: I) SAJNI JEWELLERS VS. DCIT 241 ITR 383 (GUJ) II) CIT VS. GOLANI BROTHERS 300 CTR 245 (BOM) 6 ITA NO. 3535/DEL/2016 THE LD. AR FURTHER SUBMITTED THAT PRODUCTION OF PAR TIES CANNOT BE A GROUND FOR DISALLOWANCE OF ALL PURCHASES WHEN SALES MADE OF SU CH PARTIES WERE NOT DISPUTED AS HELD IN CASE OF GANESH DAS PIARALAL JAI N VS. ITO (2017) 82 TAXMANN.COM 354 (CHANDIGARH TRIB). THE LD. AR SUBMI TTED THAT IF THE CONTENTION OF THE ASSESSING OFFICER IS ACCEPTED AND WHOLE OF THE ADDITIONS ARE MADE, THEN IT MEANS THAT 100% OF THE SALES ARE SUBJ ECTED TO TAX WITHOUT ALLOWING ANY EXPENDITURE IN RELATION THERETO AND IT WILL GIVE A DISTORTED TRADING RESULT. FROM THE COMPARATIVE CHART, THE LD. AR POIN TED OUT THAT IF WHOLE OF THE PURCHASES RS.79.13 CRORES ARE ADDED TO THE TRADING RESULTS, THEN THE GP RATE WOULD BE WORKED OUT @ 83.45% WHICH IS IMPRACTICAL I N THE TRADE. THE LD. AR SUBMITTED THE COMPARATIVE CHART OF G.P RATES AS UND ER: HIND INDUSTRIES LTD COMPARATIVE CHART OF GP RATES G. P. RATIOS AND N. P. RATIOS GROSS PROFIT RATIO FINANCIAL YEAR FINANCIAL YEAR FINANCIAL YEAR 2010-11 2009-10 2008-09 SALES 1,383,740,479 1,224,536,391 1,179,610,466 MAERIAL CONSUMED & MAN.EXPENSE 1,090,707,448 975,507,733 936,314 ,879 INCREASE/DECREASE CLSOING STOCK 70,389,451 49,230,1 30 48,350,244 GROSS PROFIT 363, 422,482 298,258,788 291,645 ,831 7 ITA NO. 3535/DEL/2016 GROSS PROFIT RATIO 26.26 24.36 24.72 NET PROFIT RATIO TOTAL INCOME 1,465,526,876 1,292,599,263 1,242,332,423 NET PROFIT BEFORE TAX 36,215,286 24,754 ,140 30,439,352 NET PROFIT AFTER TAXATION 25,421,068 16,451,3 31 15,420,518 NET PROFIT BEFORE TAX 2.62 2.02 2.58 NET PROFIT AFTER TAX 1.84 1.34 1.31 ACCEPTED ACCEPTED ACCEPTED AO PURCHASES DISALLOWED BY AO 79,13,46,369 GROSS PROFIT WOULD BE WORKED OUT 115,47,68,851 GROSS PROFIT RATE WOULD BE WORKED OUT 83.45% HOWEVER, THE FACT REMAINS THAT DURING THE YEAR UNDE R CONSIDERATION, THE GP RATE HAS BEEN DISCLOSED BY THE ASSESSEE AT A BETTER RATE IN COMPARISON TO THE PRECEDING YEAR. IN THE CASE OF BOOKS/UNVERIFIABLE P URCHASES, THE TOTAL PURCHASES CANNOT BE DISALLOWED, MORE PARTICULARLY W HEN THERE IS NO DOUBT ABOUT THE SALES DISCLOSED AND IN SUCH CASES, ONLY T HE MARGIN OF PROFIT CAN BE ADDED WHICH HAS ALREADY BEEN ADDED BY THE RESPONDEN T-ASSESSEE @ 26.26%. THE LD. AR RELIED UPON THE FOLLOWING DECISIONS: I) PR. CIT VS. MOHAMMAD HAJI ADAM & CO. ITA NO. 1004/2 016 DATED 11.02.2019 II) PR. CIT VS. PINAKI D. PANANI ITA NO. 1543/2017 DATE D 8.1.2020 (BOM) III) PR. CIT VS. RISHABDEO TECHNO CABLE ITA NO. 1330/201 7 DATED 8 ITA NO. 3535/DEL/2016 10.2.2020 (BOM) THE LD. AR SUBMITTED THAT THE PURCHASE OF FISH FROM FISHERMEN WHO ARE ILLITERATE MEN OF LIMITED MEANS AND NOT LIKE A NOR MAL BUSINESSMAN - HAVING NO FIXED PLACE OF BUSINESS - HIGHLY UNORGANIZED BUSINE SS AND NOT INCLINED TO CARRY OUT TRADE THROUGH BANKING CHANNELS, NO ADDITIONS AS HELD IN CASE OF SANCHITA MARINE PRODUCTS VS. DCIT (2007) 15 SOT 290 (MUM). T HE LD. AR FURTHER SUBMITTED THAT NO SALES CAN BE MADE WITHOUT PURCHAS ES AND HENCE CANNOT BE A CASE OF BOGUS PURCHASES AS HELD IN CASE OF BALAJI T EXTILE INDUSTRIES PVT. LTD. VS. ITO 49 ITD 177 (MUM). THE LD. AR SUBMITTED THAT THE CASE LAWS AS RELIED BY THE ASSESSING OFFICER AND THE LD. DR ARE DISTINCT O N FACTS AND ARE NOT APPLICABLE TO THE FACTS OF THE ASSESSEE. 7. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE M ATERIAL AVAILABLE ON RECORD. AS REGARDS TO GROUND NO. 1, THE CIT (A) HAS GIVEN A CATEGORICAL FINDING THAT THERE IS NO EXEMPT INCOME RECEIVED BY THE ASSE SSEE DURING THE YEAR UNDER CONSIDERATION. THIS FACT WAS NOT DISPUTED BY THE RE VENUE. THEREFORE, THE CIT(A) HAS RIGHTLY DELETED THIS DISALLOWANCE IN VIEW OF TH E CHEMINVESTMENT LTD. 61 TAXMAN.COM 118 DELHI. THUS, GROUND NO. 1 OF THE REV ENUES APPEAL IS DISMISSED. AS REGARDS TO GROUND NO. 2, IT IS PERTIN ENT TO NOTE THAT THE SALE OF THE ASSESSEE WAS NEVER DOUBTED BY THE ASSESSING OFF ICER. AS REGARDS THE PURCHASE FROM THE RECORDS AS MENTIONED IN THE ASSES SMENT ORDER ITSELF, WAS FOUND THAT QUANTITATIVE TALLY OF PURCHASES OF MEAT AND EXPORTS AND THE SAME WAS REFLECTED IN THE CREDIT COLUMN OF THE BANK ACCO UNT OF THE ASSESSEE. IT IS NOT A CASE OF THE ASSESSING OFFICER THAT PAYMENTS AGAIN ST PURCHASES HAVE BEEN MADE BY THE ASSESSEE OUT OF BOOKS OF ACCOUNTS. THE CONTENTION OF THE LD. DR ARE ALSO NOT TENABLE AS THE ASSESSEE FILED THE DETA ILS OF THE PARTIES FROM WHOM PURCHASES WERE MADE AND THE SAME IS MENTIONED IN TH E ASSESSMENT ORDER ITSELF. THE CIT(A) HAS ALSO GIVEN CATEGORICAL FINDI NG THAT ONLY 20% OF THE PURCHASES WHERE DISALLOWED ON ACCOUNT OF CASH PAYM ENT WHICH WAS DULY REFLECTED IN THE BOOKS OF ACCOUNT OF THE ASSESSEE. THE CASE LAWS REFERRED BY THE LD. DR ARE FACTUALLY NOT RELEVANT IN THE PRESENT CA SE AND ARE DISTINGUISHABLE. 9 ITA NO. 3535/DEL/2016 THUS, THERE IS NO NEED TO INTERFERE WITH THE FINDIN GS OF THE CIT(A). THE APPEAL OF THE REVENUE IS DISMISSED. 8. IN RESULT, APPEAL OF THE REVENUE IS DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON 18 TH MARCH, 2020. SD/- SD/- (N. K. BILLAIYA) (SUCHITRA KAMBLE) ACCOUNTANT MEMBER JUDICIAL MEMBE R DATED: 18/03/2020 R. NAHEED COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI 10 ITA NO. 3535/DEL/2016 DATE OF DICTATION 20.02.2020 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 20.02.2020 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE OTHER MEMBER DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR. PS/PS DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE DICTATING MEMBER FOR PRONOUNCEMENT DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR. PS/PS 1 9 .0 3 .2020 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT 1 9 .0 3 .2020 DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 1 9 .0 3 .2020 DATE ON WHICH THE FILE GOES TO THE HEAD CLERK THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT REGISTRAR FOR SIGNATURE ON THE ORDER DATE OF DISPATCH OF THE ORDER