M/s. Shine Pharmaceuticals Limited, Vadodara V. DCIT, Circle-(2)(1)(1), Baroda

ITA 362/AHD/2018

• Counselvise Citation: [2019] 115 COUNSELVISE.COM (IT) 6335 (ITAT-AHMEDABAD)
• Duration Of Justice: 1 year(s) 8 month(s) 3 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 17-10-2019
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: C
• Assessment Year: 2014-2015
• Appeal Filed On: 14-02-2018
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: LALIT P JAIN
• Keywords: Gift; Business income
• Section: 43B; 143(3); 37(1); 139(1); 37

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL C BENCH, AHMEDABAD BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER & MS. MADHUMITA ROY, JUDICIAL MEMBER ITA NO. 362/AHD/2018 (ASSESSMENT YEAR : 2014-15) M/S. SHINE PHARMACEUTICALS LTD., 308-310, DWARKESH COMPLEX, SUN PHARMA ROAD, ATLADARA, VADODARA 390 020. VS. DY. COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), BARODA. [PAN NO. AAECS 2660 M] (APPELLANT) .. (RESPONDENT) APPELLANT BY : MS. URVASHI SODHAN, A.R. RESPONDENT BY : SHRI LALIT P. JAIN, SR. D.R. DATE OF HEARING 14.10.2019 DATE OF PRONOUNCEMENT 17.10.2019 O R D E R PER MS. MADHUMITA ROY JUDICIAL MEMBER: THE INSTANT APPEAL FILED BY THE ASSESSEE IS DIRECTE D AGAINST THE ORDER DATED 22.12.2017 PASSED BY THE COMMISSIONER OF INCOME TAX (APPEALS) - 2, VADODARA ARISING OUT OF THE ORDER DATED 20.12.2016 PASSED BY THE DCI T, CIRCLE 2(1)(1), BARODA UNDER SECTION 143(3) OF THE INCOME TAX ACT, 1961 (H EREINAFTER REFERRED AS TO THE ACT) FOR THE ASSESSMENT YEAR (A.Y.) 2014-15 WITH THE FOLLOWING GROUNDS: 1) THE LEARNED FOUND THAT THE ASSESSEE HAS NOT MADE T HE EMPLOYEE'S CONTRIBUTION PAYMENTS TOWARDS ESIC BEFORE DUE DATE SPECIFIED UNDER SECTION 36(1)(VA) OF THE ACT AND HENCE MADE THE ADD ITION OF RS. 3,79,404/- TO THE TOTAL INCOME OF THE ASSESSEE. AND COMMISSION ER OF THE INCOME TAX UPHELD THE DECISION OF THE AO. YOUR APPELLANT SUBMITS THAT SAME IS NOT JUSTIFIED A ND THEREFORE BE DELETED - 2 - ITA NO.362/AHD/2018 SHINE PHARMACEUTICALS LTD. VS. DCIT ASST.YEAR 2014-15 2) THE LEARNED AO OBSERVED THAT THE EXPENDITURE AMOUNT ING TO RS. 19,45,443/- WAS INCURRED FOR THE PURPOSES LIKE DISTRIBUTING GIF TS, PROVIDING HOSPITALITY TO THE DOCTORS/ MEDICAL PRACTITIONERS. THE LEARNED AO DISALLOWED RS.19,45,443/- BY REASONING THAT THE AN AMOUNT OF R S. 14,45,443/- WAS INCURRED TOWARDS THE PURCHASE OF LAPTOP, MOBILE, WA TCHES, AC MACHINES, TREADMILL MACHINES ETC WHICH IS IN THE NATURE OF GI FTS FOR DOCTORS AND PRACTITIONERS, AND AN ADHOC DISALLOWANCE OF RS. 500 000/- IS MADE ON ACCOUNT OF HAVING INCURRED ON THE LODGING, BOARDING AND TRAVELLING OF THE DOCTORS/MEDICAL PRACTITIONERS EXPLANATION TO SECTIO N 37 OF THE IT ACT, 1961 IS INVOKED. AND COMMISSIONER OF INCOME TAX (APPEAL) -2 HAS DISMISSED THE APPEAL. YOUR APPELLANT SUBMITS THAT SAME IS NOT JUS TIFIED AND THEREFORE BE DELETED YOUR APPELLANT CRAVES LEAVE TO ADD TO, ALTER, TO AM END OR TO DELETE ANY OR ALL THE GROUNDS OF APPEAL. 2. THE FIRST GROUND RELATES TO ADDITION OF RS.3,79, 404/- ON THE GROUND THAT THE ASSESSEE HAS NOT MADE THE EMPLOYEES CONTRIBUTION P AYMENTS TOWARDS ESIC BEFORE DUE DATE SPECIFIED UNDER SECTION 36(1)(VA) OF THE ACT, WHICH HAS BEEN ADDED BY THE AUTHORITIES BELOW RELYING UPON THE JUDGMENT PRONOUNCED BY THE H ONBLE JURISDICTIONAL HIGH COURT IN THE CASE OF CIT-VS-GUJARAT STATE ROAD TRANSPORT COR PORATION (2014) 223 TAXMAN 398 (GUJ.) WHEREIN IT HAS BEEN HELD THAT THE ASSESSEE S HALL NOT BE ENTITLED TO DEDUCTION OF PAYMENTS OF EMPLOYEES CONTRIBUTION TO ESIC ACCOUNT IF IT IS PAID TO THE CONCERNED ACCOUNT AFTER THE DUE DATE AS SPECIFIED U/S 36(1)(V A), THOUGH HE DEPOSITS THE SAME BEFORE THE DUE DATE PRESCRIBED UNDER SECTION 43B I.E., PRI OR TO FILING OF RETURN U/S 139(1) OF THE ACT WHICH ACCORDING TO US IS JUST AND PROPER, WITHO UT ANY INFIRMITY. HENCE, WE FIND NO MERIT IN THIS GROUND OF APPEAL PREFERRED BY THE ASS ESSEE. THE SAME IS THUS, DISMISSED. 3. THE SECOND GROUND RELATES TO DISALLOWANCE OF EXP ENDITURE AMOUNTING TO RS.19,45,443/-, WHICH WAS INCURRED FOR THE PURPOSE OF DISTRIBUTING GIFTS, PROVIDING HOSPITALITY TO THE DOCTORS AND/OR MEDICAL PRACTITIO NERS; OUT OF WHICH RS.14,45,443/- WAS INCURRED TOWARDS THE PURCHASE OF LAPTOP, MOBILE, WA TCHES, AC MACHINES, TREADMILL MACHINES ETC IN THE NATURE OF GIFTS FOR DOCTORS AND PRACTITIONERS AND THE REMAINING BALANCE OF RS.5,00,000/- HAS BEEN DISALLOWED ON AD HOC BASI S ON ACCOUNT OF HAVING BEEN INCURRED - 3 - ITA NO.362/AHD/2018 SHINE PHARMACEUTICALS LTD. VS. DCIT ASST.YEAR 2014-15 ON THE LODGING, BOARDING AND TRAVELLING OF THE DOCT ORS, MEDICAL PRACTITIONERS UPON INVOCATION OF SECTION 37 OF THE I. T. ACT, 1961 AND THE AMENDED PROVISION OF INDIAN MEDICAL COUNCIL (PROFESSIONAL CONDUCT, ETIQUETTE AN D ETHICS) REGULATIONS, 2002 ON 10 DECEMBER, 2009 WHEREBY AND WHEREUNDER THE MCI IMPOS ED PROHIBITION ON MEDICAL PRACTITIONERS FROM INTER ALIA, ACCEPTING GIFTS, TRA VEL FACILITIES, HOSPITALITY, CASH OR MONETARY GRANTS. THE CBDT CIRCULAR BEING NO. 5/2012 (F. NO. 225/142/2012-ITA.II), DATED 01.08.2012 HAS ALSO BEEN RELIED UPON BY THE AUTHORI TIES BELOW. 4. THE LEARNED ADVOCATE APPEARING FOR THE ASSESSEE FAIRLY SUBMITTED BEFORE US THAT THE ISSUE HAS ALREADY BEEN DECIDED BY THE CO-ORDINA TE BENCH IN ASSESSEES OWN CASE IN ITA NO.637/AHD/2017 FOR A.Y. 2013-14 WHEREBY AND WH EREUNDER THE DISALLOWANCE MADE BY THE AUTHORITIES BELOW HAS BEEN UPHELD COPY WHEREOF HAS ALSO BEEN SUBMITTED BEFORE US. THE LEARNED DR ALSO RELIED UPON THE ORDE R PASSED BY THE AUTHORITIES BELOW. 5. HEARD THE RESPECTIVE PARTIES, PERUSED THE RELEVA NT MATERIALS AVAILABLE ON RECORD AND ALSO THE ORDER PASSED BY THE CO-ORDINATE BENCH ON T HE IDENTICAL ISSUE. THE RELEVANT PORTION OF THE SAME IS AS FOLLOWS: 5.4. HOWEVER, THE ASSESSING OFFICER FOUND THAT TH ERE ARE CERTAIN EXPENSES INCURRED BY THE ASSESSEE TOWARDS THE PURCHASE OF LA PTOPS, WRIST WATCHES, MOBILE PHONES, AND CAMERA, ETC. AMOUNTING TO RS. 13,16,620 /- WHICH WERE LIKE THE GIFTS TO THE DOCTORS/MEDICAL PRACTITIONERS. THESE GIFTS ITEM S CANNOT BE CATEGORIZED AS SALES PROMOTION EXPENSES. THEREFORE, THE SAME CANNOT BE A LLOWED AS DEDUCTION AS PER THE CBDT CIRCULAR AND MEDICAL COUNCIL OF INDIA. 5.5. THE AO ALSO OBSERVED THAT THE ASSESSEE HAS NO T FURNISHED THE NECESSARY DETAILS DEPICTING THE BENEFITS IN MONETARY/NON-MONE TARY BENEFIT EXTENDED TO THE DOCTORS/MEDICAL PRACTITIONERS. THE ASSESSING OFFICE R ALSO NOTED THAT THERE WERE NOT SUFFICIENT DETAILS FURNISHED IN SUPPORT OF TRAV ELING EXPENSES TO JUSTIFY THAT THE DOCTORS AND MEDICAL PRACTITIONERS DID NOT INCUR THE SE EXPENSES. IN THE ABSENCE OF NECESSARY EVIDENCE, THE ASSESSING OFFICER MADE THE DISALLOWANCE OF RS.5,00,000/- FOR BENEFIT EXTENDED TO THE DOCTORS/MEDICAL PRACTIT IONERS IN CONTRAVENTION TO THE PROVISIONS OF CBDT CIRCULAR/MEDICAL COUNCIL OF INDI A AS DISCUSSED ABOVE. THEREFORE, THE ASSESSING OFFICER PROPOSED TO MAKE A DISALLOWANCE OF RS.5,00,000/- - 4 - ITA NO.362/AHD/2018 SHINE PHARMACEUTICALS LTD. VS. DCIT ASST.YEAR 2014-15 WHICH WAS AGREED BY THE LD. REPRESENTATIVE OF THE A SSESSEE AND MANAGING DIRECTOR OF THE ASSESSEE. 5.6. IN VIEW OF THE ABOVE, THE ASSESSING OFFICER M ADE THE DISALLOWANCE OF RS.18,16,120/- AND ADDED TO THE TOTAL INCOME OF THE ASSESSEE. 6. THE AGGRIEVED ASSESSEE PREFERRED AN APPEAL TO THE LD.CIT(A). THE ASSESSEE BEFORE THE LD. CIT(A) SUBMITTED THAT THE CIRCULAR ISSUED BY THE CBDT DATE D 01/08/2012 WHICH IS PROSPECTIVE IN NATURE. THEREFORE, THERE CANNOT BE A NY DISALLOWANCE OF THE EXPENSES BEFORE THE DATE OF THE ISSUE OF THE CIRCULAR. 6.1. THE NECESSARY DETAILS WERE FURNISHED TO AO ON ACCOUNT OF SALES PROMOTION EXPENSES. BUT THE ASSESSING OFFICER WITHOUT POINTIN G OUT ANY SPECIFIC DEFECT HAS MADE THE AD-HOC DISALLOWANCE OF RS.5,00,000/- WHICH IS NOT PERMISSIBLE UNDER THE LAW. 6.2. THE CIRCULARS ARE BINDING ON THE INCOME TAX A UTHORITIES, BUT THE SAME CANNOT BE USED AGAINST THE ASSESSEE. 6.3. HOWEVER, THE LD. CIT(A) CONFIRMED THE DISALLO WANCE MADE BY THE ASSESSING OFFICER BY OBSERVING THAT SIMILAR KIND OF DISALLOWANCES WAS MADE IN THE EARLIER ASSESSMENT YEARS. THE MANAGING DIRECTOR OF THE ASSESSEE DULY ADMITTED THE AD-HOC DISALLOWANCE OF RS. 5,00,000/- DURING TH E HEARING. THUS, THE LD. CIT(A) CONFIRMED THE ORDER OF THE ASSESSING OFFICER . 7. BEING AGGRIEVED BY THE ORDER OF LD. CIT(A), THE ASSESSEE IS IN APPEAL BEFORE US. 8. THE LD.AR BEFORE US FILED A PAPER BOOK RUNNING FROM PAGES 1 TO 25 AND SUBMITTED THAT THERE WAS NO BENEFIT EXTENDED TO THE DOCTORS/MEDICAL PRACTITIONERS. ALL THESE EXPENSES ON THE GIFT ITEMS WERE INCURRED TO PROVIDE THE BENEFIT TO THE MEDICAL STORES AND CHEMIST SHOPS. 9. ON THE OTHER HAND, THE LD. DR SUBMITTED THAT TH E DISALLOWANCE MADE BY THE LOWER AUTHORITIES REPRESENT LESS THAN 1% OF THE TOTAL SALES PROMOTION EXPENSES. THE LD. DR VEHEMENTLY SUPPORTED THE ORDERS OF THE A UTHORITIES BELOW. 10. WE HAVE HEARD THE RIVAL CONTENTIONS AND PERUSE D THE MATERIALS AVAILABLE ON RECORD. IN THE INSTANT CASE, THE AO HAS MADE THE AD DITION TO THE TOTAL INCOME OF THE ASSESSEE FOR TWO COUNTS AS DISCUSSED BELOW. I. THE EXPENSES INCURRED ON THE PURCHASE OF LAPTOPS, W RIST WATCHES, MOBILE PHONES, AND CAMERAS, ETC. RS.13,16,120/- WAS TREATE D AS GIFTS GIVEN TO THE - 5 - ITA NO.362/AHD/2018 SHINE PHARMACEUTICALS LTD. VS. DCIT ASST.YEAR 2014-15 DOCTORS/MEDICAL PRACTITIONERS BY THE AO, THOUGH THE ASSESSEE CLAIMED THAT THESE ITEMS WERE GIVEN TO THE DEALERS. BUT THE AO D ISBELIEVED THE CONTENTION OF THE ASSESSEE BY OBSERVING THAT THE ASSESSEE FAIL ED TO FURNISH THE DOCUMENTARY EVIDENCE. THE ASSESSEE ALSO FAILED TO F URNISH ANY SCHEME UNDER WHICH THESE ITEMS WERE GIVEN TO THE DEALERS. II. THERE WAS NO DETAIL FURNISHED BY THE ASSESSEE EVIDE NCING THAT THE GIFT ITEMS WERE NOT GIVEN TO THE DOCTORS/ MEDICAL PRACTITIONER S. IN THE ABSENCE OF THE DETAILS OF THE ACTUAL RECIPIENT OF THE GIFT ARTICLE , THE AO MADE AN AD-HOC DISALLOWANCE OF RS. 5 LACS FOR WHICH THE ASSESSEE A GREED. 10.1. THE LD. CIT-A SUBSEQUENTLY CONFIRMED THE VIE W TAKEN BY THE AO. THERE IS NO DISPUTE THAT THE GIFTS, FREEBIES AND ANY OTHER B ENEFIT TO THE DOCTORS ARE PROHIBITED AS PER EXPLANATION TO SECTION 37 OF THE ACT. THERE IS ALSO A CIRCULAR BEARING NUMBER 5/2012 (F.NO.225/142/2012-ITA.II) DA TED 1ST AUGUST 2012 ISSUED BY THE CBDT WHICH PROHIBITS SUCH GIFTS OF THE DOCTO RS. ACCORDING TO THE CIRCULAR, THE DEDUCTION TO THE PHARMACEUTICAL COMPANY IN RESP ECT OF SUCH EXPENSES WILL NOT BE AVAILABLE. THE HONBLE HIMACHAL PRADESH HIGH COU RT ALSO UPHELD THE VALIDITY OF THE CIRCULAR IN THE CASE OF CONFEDERATION OF IND IA PHARMACEUTICALS INDUSTRY (SSI) VS. CBDT REPORTED IN 353 ITR 388 WHEREIN IT W AS HELD AS UNDER: SHRI VISHAL MOHAN, ADVOCATE, ON BEHALF OF THE PETI TIONER CONTENDS THAT THE CIRCULAR GOES BEYOND THE SECTION ITSELF. WE ARE NOT IN AGREEMENT WITH THIS SUBMISSION. THE EXPLANATION TO SECTION 37(1) MAKES IT CLEAR THAT ANY EXPENDITURE INCURRED BY AN ASSESSEE FOR ANY PURPOSE WHICH IS PROHIBITED BY LAW SHALL NOT BE DEEMED TO HAVE BEEN INCURRED FOR T HE PURPOSE OF BUSINESS OR PROFESSION. THE SUM AND SUBSTANCE OF THE CIRCULA RS ALSO THE SAME. IN CASE THE ASSESSING AUTHORITIES ARE NOT PROPERLY UND ERSTANDING THE CIRCULAR THEN THE REMEDY LIES FOR EACH INDIVIDUAL ASSESSEE T O FILE APPEALS UNDER THE INCOME-TAX ACT BUT THE CIRCULAR WHICH IS TOTALLY IN LINE WITH SECTION 37(1) CANNOT BE SAID TO BE ILLEGAL. IN FACT PARAGRAPH 4 O F THE CIRCULAR QUOTED HEREINABOVE ITSELF CLARIFIES THAT THE VALUE OF THE FREEBIES ENJOYED BY THE MEDICAL PRACTITIONER IS ALSO TAXABLE AS BUSINESS IN COME OR INCOME FROM OTHER SOURCES DEPENDING ON THE FACTS OF EACH CASE. THEREFORE, IF THE ASSESSEE SATISFIES THE ASSESSING AUTHORITY THAT THE EXPENDITURE IS NOT IN VIOLATION OF THE REGULATIONS FRAMED BY THE MEDICAL COUNCIL THEN IT MAY LEGITIMATELY CLAIM A DEDUCTION, BUT IT IS FOR THE A SSESSEE TO SATISFY THE ASSESSING OFFICER THAT THE EXPENSE IS NOT IN VIOLAT ION OF THE MEDICAL COUNCIL REGULATIONS REFERRED TO ABOVE. - 6 - ITA NO.362/AHD/2018 SHINE PHARMACEUTICALS LTD. VS. DCIT ASST.YEAR 2014-15 10.2. DURING THE HEARING THE LD. COUNSEL FOR THE A SSESSEE HAS NOT AGITATED FOR THE APPLICABILITY OF THE CIRCULAR ISSUED BY THE CBDT AS DISCUSSED ABOVE. ACCORDINGLY, THERE REMAINS NO CONFUSION THAT ANY EXPENSE INCURRE D BY THE ASSESSEE TO EXTEND THE BENEFIT TO THE DOCTORS WILL NOT BE ALLOWED AS A DED UCTION BY THE EXPLANATION OF SECTION 37 OF THE ACT AS WELL AS THE CIRCULAR ISSUE D BY THE CBDT THE AS DISCUSSED ABOVE. 10.3. THE ARGUMENT OF THE LD. COUNSEL FOR THE ASSE SSEE IS THAT THESE BENEFITS WERE GIVEN TO THE MEDICAL STORE/CHEMIST SHOPS. AS PER TH E ITA NO.637/AHD/2017 SHINE PHARMACEUTICALS LTD. VS. DCIT ASST.YEAR 2013-14 - 9 - ASSESSEE, THERE WERE NO BENEFITS GIVEN BY THE ASSESSEE TO THE DOCTORS/MEDIC AL PRACTITIONER. HOWEVER, FROM THE ORDER OF THE AO, WE NOTE THAT THE ASSESSEE HAS NOT FURNISHED SUFFICIENT DOCUMENTARY PIECES OF EVIDENCE SUGGESTING THAT THE DEALERS HAVE NOT PASSED ON THESE FREEBIES TO THE DOCTORS. THEREFORE THE ADDITI ON WAS MADE BY THE AO. 10.4. EVEN BEFORE US THE LD. COUNSEL FOR THE ASSES SEE HAS NOT PRODUCED ANY EVIDENCE TO PROVE THAT THERE WAS NO BENEFIT EXTENDE D TO THE DOCTORS/MEDICAL PRACTITIONERS OUT OF THE PURCHASES OF LAPTOPS, WRIS T WATCHES, MOBILE PHONES, CAMERAS, ETC. IN THE ABSENCE OF ANY DOCUMENTARY EVI DENCE, WE ARE NOT INCLINED TO DISTURB THE FINDING OF THE LOWER AUTHORITIES. 10.5. SIMILARLY, WE ALSO NOTE THAT THE ASSESSEE DU LY ADMITTED THE DISALLOWANCE OF RS. 5 LACS MADE BY THE AO ON AN AD-HOC BASIS DURING THE ASSESSMENT PROCEEDINGS. THE AO MADE THE ADDITION BY OBSERVING THAT THE ASSE SSEE FAILED TO FURNISH THE DETAILS OF THE ACTUAL RECIPIENT OF THESE GIFT ARTIC LES. THE ASSESSEE HAS ALSO INCURRED TRAVELING EXPENSES WHICH WERE CLAIMED BY THE ASSESS EE FOR THE TRAVELING OF THE MEDICAL REPRESENTATIVES. BUT THE ASSESSEE FAILED TO FILE THE REQUISITE DOCUMENTS EVIDENCING THAT THERE WAS NO BENEFIT EXTENDED TO TH E DOCTORS /MEDICAL PRACTITIONERS OUT OF SUCH TRAVELING EXPENSES. THEREFORE THE ADDIT ION WAS MADE BY THE AO ON AN AD-HOC BASIS. IN THIS REGARD, WE ALSO NOTE THAT THE LD. COUNSEL FOR THE ASSESSEE HAS ALSO NOT PRODUCED ANY EVIDENCE BEFORE US TO PROVE T HAT THE DOCTORS WERE NOT THE ACTUAL RECIPIENT OF THESE GIFT ARTICLES. THUS IN TH E ABSENCE OF NECESSARY DOCUMENTARY EVIDENCE THE AO HAD NO ALTERNATIVE EXCE PT TO MAKE THE DISALLOWANCE ON AN AD-HOC BASIS. THUS WE ARE INCLINED NOT TO DIS TURB THE FINDING OF THE LOWER AUTHORITIES. ACCORDINGLY, WE DISMISS THE GROUND OF APPEAL OF THE ASSESSEE. 11. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS D ISMISSED. - 7 - ITA NO.362/AHD/2018 SHINE PHARMACEUTICALS LTD. VS. DCIT ASST.YEAR 2014-15 RESPECTFULLY RELYING UPON THE ORDER PASSED BY THE C O-ORDINATE BENCH, WE FIND NO REASON TO DEVIATE FROM THE FINDING MADE THEREIN AND HENCE THE GROUND OF APPEAL PREFERRED BY THE ASSESSEE IS DISMISSED. 6. IN THE RESULT, ASSESSEES APPEAL IS DISMISSED. THIS ORDER PRONOUNCED IN OPEN COURT ON 17/10/2019 SD/- SD/- ( WASEEM AHMED ) ( MS. MADHUMITA ROY ) ACCOUNTANT MEMBER JUDICIAL MEMBER AHMEDABAD; DATED 17/10/2019 PRITI YADAV, SR.PS / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. / CONCERNED CIT 4. ) ( / THE CIT(A)-2, VADODARA. 5. , '#$$ / DR, ITAT, AHMEDABAD 6. %& '( / GUARD FILE. / BY ORDER, //TRUE COPY// / (DY./ASSTT. REGISTRAR) !'# / ITAT, AHMEDABAD 1. DATE OF DICTATION 14.10.2019 ( DICTATION PAGES 3 ) 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 15.10.2019 3. OTHER MEMBER. 4. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR. P .S./P.S 17.10.2019 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. 7. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 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