Maruti Suzuki India Ltd., New Delhi V. JCIT (OSD), New Delhi

ITA 469/DEL/2014

• Counselvise Citation: [2021] 108 COUNSELVISE.COM (IT) 9728 (ITAT-DELHI)
• Duration Of Justice: 7 year(s) 1 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-03-2021
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: E
• Next Hearing Date: 27-04-2017
• Assessment Year: 1995-1996
• Appeal Filed On: 27-01-2014
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: PRAMITA M BISWAS
• Section: 244A; 234B; 143(1)

Judgement Text

ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 1 OF 10 IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: E: NEW DELHI) (THROUGH VIDEO CONFERENCING) BEFORE SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER ITA NO:- 469/DEL/2014 ( ASSESSMENT YEAR: 1995-96) MARUTI SUZUKI INDIA LTD., PLOT NO. 1, NELSON MANDELA ROAD, VASANT KUNJ, NEW DELHI. VS. JCIT (OSD), CIRCLE- 6(1), NEW DELHI. APPELLANT RESPONDENT PAN NO: AAACM0829Q ITA NO:- 470/DEL/2014 ( ASSESSMENT YEAR: 1996-97) MARUTI SUZUKI INDIA LTD., PLOT NO. 1, NELSON MANDELA ROAD, VASANT KUNJ, NEW DELHI. VS. JCIT (OSD), CIRCLE- 6(1), NEW DELHI. APPELLANT RESPONDENT PAN NO: AAACM0829Q ITA NO:- 471/DEL/2014 ( ASSESSMENT YEAR: 1997-98) MARUTI SUZUKI INDIA LTD., PLOT NO. 1, NELSON MANDELA ROAD, VASANT KUNJ, NEW DELHI. VS. JCIT (OSD), CIRCLE- 6(1), NEW DELHI. APPELLANT RESPONDENT PAN NO: AAACM0829Q ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 2 OF 10 ASSESSEE BY : SHRI AJAY VOHTRA, SR. ADV. SHRI ADITYA VOHRA, ADV . MS. SOMIYA JAIN, CA REVENUE BY : MS. PRAMITA M. BISWAS, CIT(DR) ITA NO:- 600/DEL/2014 ( ASSESSMENT YEAR: 1995-96) DCIT, CIRCLE- 6(1), NEW DELHI. VS. MARUTI SUZUKI INDIA LTD., PLOT NO. 1, NELSON MANDELA ROAD, VASANT KUNJ, NEW DELHI. APPELLANT RESPONDENT PAN NO: AAACM0829Q ITA NO:- 601/DEL/2014 ( ASSESSMENT YEAR: 1996-97) DCIT, CIRCLE- 6(1), NEW DELHI. VS. MARUTI SUZUKI INDIA LTD., PLOT NO. 1, NELSON MANDELA ROAD, VASANT KUNJ, NEW DELHI. APPELLANT RESPONDENT PAN NO: AAACM0829Q ITA NO:- 602/DEL/2014 ( ASSESSMENT YEAR: 1997-98) DCIT, CIRCLE- 6(1), NEW DELHI. VS. MARUTI SUZUKI INDIA LTD., PLOT NO. 1, NELSON MANDELA ROAD, VASANT KUNJ, NEW DELHI. APPELLANT RESPONDENT PAN NO: AAACM0829Q ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 3 OF 10 REVENUE BY : MS. PARAMITA M. BISWAS, CIT(DR) ASSESSEE BY : SHRI AJAY VOHRA, SR. ADV. SHRI ADITYA VOHRA, ADV . MS. SOMYA JAIN, CA PER BENCH THE AFOREMENTIONED SIX APPEALS IN THE CASE OF THE A SSESSEE AND REVENUE ARE TAKEN UP TOGETHER FOR THE SAKE OF CONVENIENCE AND BREVITY ; AND ARE HEREBY DISPOSED OFF THROUGH THIS CONSOLIDATED ORDER. GROUNDS TAKEN IN THESE SI X APPEALS OF ASSESSEE AS WELL AS REVENUE ARE AS UNDER: ITA NO.- 469/DEL/2014 1.0 THAT THE CIT(APPEALS) ERRED ON FACTS AND IN LA W IN NOT RECTIFYING THE ERRORS COMMITTED BY THE ASSESSING OFFICER IN COMPUTING THE INTEREST UNDER SECTION 244A OF THE INCOME TAX ACT, 1961. THE APPELLANT PRAYS LEAVE TO ADD, AMEND, ALTER, DEL ETE OR FOREGO ANY OF THE GROUNDS EITHER BEFORE OR DURING THE COURSE OF HEARI NG . ITA NO.- 470/DEL/2014 1.0 THAT THE CIT(APPEALS) ERRED ON FACTS AND IN LAW IN NOT RECTIFYING THE ERRORS COMMITTED BY THE ASSESSING OFFICER IN COMPUTING THE INTEREST UNDER SECTION 244A OF THE INCOME TAX ACT, 1961. THE APPELLANT PRAYS LEAVE TO ADD, AMEND, ALTER, DEL ETE OR FOREGO ANY OF THE GROUNDS EITHER BEFORE OR DURING THE COURSE OF HEARI NG . ITA NO.- 471/DEL/2014 1.0 THAT THE CIT (APPEALS) HAS ERRED ON FACTS AND IN LAW IN REJECTING THE APPEAL FILED BY THE APPELLANT WITHOUT GIVING ANY FINDING O N THE LEGAL GROUNDS RAISED BY THE APPELLANT. ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 4 OF 10 2.0 THAT THE CIT (APPEALS) ERRED ON FACTS AND IN LA W IN CONFIRMING THE ACTION OF THE ASSESSING OFFICER IN NOT GRANTING INTEREST UNDE R SECTION 244A OF THE INCOME TAX ACT, 1961 (THE ACT) ON THE AMOUNT OF REFUND, BEING THE EXCESS OF TAX LIABILITY ON THE ASSESSED INCOME OVER THE TAXES PAI D UNDER SECTION 143(1) OF THE ACT. 3.0 THAT THE CIT (APPEALS) ERRED ON FACTS AND IN L AW IN CONCLUDING THAT FOR GIVING EFFECT TO THE PROVISIONS OF SECTION 244A(3), THE LIMITATION AS PER THE PROVISO TO 244A(1)(A) OF THE ACT WOULD APPLY. THAT APPELLANT PRAYS LEAVE TO ADD, AMEND, ALTER, DE LETE OR FOREGO ANY OF THE GROUNDS EITHER BEFORE OR DURING THE COURSE OF HEARI NG . ITA NO.- 600/DEL/2014 1. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CA SE & IN LAW, THE LD. CIT(A) ERRED IN DIRECTING THE A.O. TO ALLOW INTEREST U/S 2 44A TO THE ASSESSEE FOR THE MONTH IN WHICH PAYMENTS /ADJUSTMENTS WERE MADE ON THE LAS T DAY OF THE MONTH? 2. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CA SE & IN LAW, THE LD. CIT(A) ERRED IN HOLDING THAT FEW HOURS OF THE DAY CONSTITU TE PART OF THE MONTH WHEREAS FOR CONSTITUTING PART OF THE MONTH AT LEAST ONE DAY SHO ULD HAVE BEEN COMPLETED ? 3. THAT THE ORDER OF THE LD. CIT(A) IS ERRONEOUS AN D IS NOT TENABLE ON FACTS AND IN LAW. 4. THAT THE GROUNDS OF APPEAL ARE WITHOUT PREJUDICE TO EACH OTHER. 5. THAT THE APPELLANT CRAVES LEAVE TO ADD, ALTER, AMEND OR FORGO ANY GROUND(S) OF APPEAL EITHER BEFORE OR AT THE TIME OF HEARING OF T HE APPEAL. ITA NO. 601/DEL/2014 1. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CA SE & IN LAW, THE LD. CIT(A) ERRED IN DIRECTING THE A.O. TO ALLOW INTEREST U/S 2 44A TO THE ASSESSEE FOR THE MONTH IN WHICH PAYMENTS /ADJUSTMENTS WERE MADE ON THE LAS T DAY OF THE MONTH? 2. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CA SE & IN LAW, THE LD. CIT(A) ERRED IN HOLDING THAT FEW HOURS OF THE DAY CONSTITU TE PART OF THE MONTH WHEREAS FOR CONSTITUTING PART OF THE MONTH AT LEAST ONE DAY SHO ULD HAVE BEEN COMPLETED ? 3. THAT THE ORDER OF THE LD. CIT(A) IS ERRONEOUS AN D IS NOT TENABLE ON FACTS AND IN LAW. ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 5 OF 10 4. THAT THE GROUNDS OF APPEAL ARE WITHOUT PREJUDICE TO EACH OTHER. 5. THAT THE APPELLANT CRAVES LEAVE TO ADD, ALTER, AMEND OR FORGO ANY GROUND(S) OF APPEAL EITHER BEFORE OR AT THE TIME OF HEARING OF T HE APPEAL. ITA NO. 602/DEL/2014 1. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE C ASE & IN LAW, THE LD. CIT(A) ERRED IN DIRECTING THE A.O. TO GIVE REFUND OF RS. 3 ,20,87,719/- TO THE ASSESSEE WITHOUT EITHER VERIFYING THE RECORDS OF ALLOWING TH E A.O. AN OPPORTUNITY TO EXPLAIN? 2. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CA SE & IN LAW, THE LD. CIT(A) ERRED IN DIRECTING THE A.O. TO GIVE REFUND OF RS. 3 ,20,87,719/- TO THE ASSESSEE WITHOUT APPRECIATING THE FACT THAT REFUND OF RS. 3, 20,87,719/- HAS ALREADY BEEN GRANTED TO THE ASSESSEE? 3. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CA SE & IN LAW, THE LD. CIT(A) ERRED IN DIRECTING THE A.O. TO ALLOW INTEREST U/S 2 44A TO THE ASSESSEE FOR THE MONTH IN WHICH PAYMENTS /ADJUSTMENTS WERE MADE ON THE LAS T DAY OF THE MONTH? 4. WHETHER ON THE FACTS AND CIRCUMSTANCES OF THE CA SE & IN LAW, THE LD. CIT(A) ERRED IN HOLDING THAT FEW HOURS OF THE DAY CONSTITU TE PART OF THE MONTH WHEREAS FOR CONSTITUTING PART OF THE MONTH AT LEAST ONE DAY SHO ULD HAVE BEEN COMPLETED? 5. THAT THE ORDER OF THE LD. CIT(A) IS ERRONEOUS AN D IS NOT TENABLE ON FACTS AND IN LAW. 6. THAT THE GROUNDS OF APPEAL ARE WITHOUT PREJUDICE TO EACH OTHER. 7. THAT THE APPELLANT CRAVES TO ADD, AMEND OR FORGO ANY GROUND(S) OF APPEAL EITHER BEFORE OR AT THE TIME OF HEARING OF THE APPEAL. (B) IN ALL THESE SIX APPEALS, THREE APPEALS FILED BY R EVENUE AND THREE APPEALS FILED BY THE ASSESSEE; THE DISPUTES PERTAIN TO THE SOLE I SSUE OF INTEREST UNDER SECTION 244A OF INCOME TAX ACT, 1961 (I.T. ACT, FOR SHORT) PAYABL E BY REVENUE TO THE ASSESSEE. VIDE IMPUGNED APPELLATE ORDER EACH DATED 29.11.2013, OF THE LD. CIT(A) FOR ASSESSMENT YEARS 1995-96, 1996-97, AND 1997-98 RESPECTIVELY, T HE LD. CIT(A) EXPRESSED THE VIEW THAT INTEREST SHOULD BE GIVEN TO THE ASSESSEE UNDER SECTION 244A OF I.T. ACT FOR THE FULL ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 6 OF 10 MONTH EVEN IF TAX IS PAID BY THE ASSESSEE ON THE LA ST DAY OF THE MONTH. VIDE ITA NOS. 600/DEL/2014, 601/DEL/2014 AND 602/DEL/2014 FOR ASS ESSMENT YEARS 1995-96, 1996- 97, AND 1997-98 RESPECTIVELY FILED BY REVENUE AGAIN ST THE AFORESAID IMPUGNED APPELLATE ORDERS OF THE LD. CIT(A); THIS DIRECTION OF THE LD. CIT(A) HAS BEEN DISPUTED ON THE GROUND THAT PAYMENTS OF TAX / ADJUSTMENTS WERE MADE ON THE LAST DAY OF THE MONTH. REVENUE IS OF THE VIEW THAT FOR CONSTITUTING PART O F THE MONTH, AT LEAST ONE DAY SHOULD HAVE BEEN COMPLETED AND A FEW HOURS OF THE DAY DO N OT CONSTITUTE PART OF THE MONTH. AT THE TIME OF HEARING BEFORE US, THE REPRESENTATIV ES OF BOTH SIDES; NAMELY MS. PARAMITA M. BISWAS, COMMISSIONER OF INCOME TAX (DEP ARTMENTAL REPRESENTATIVE) FROM REVENUES SIDE AND SHRI AJAY VOHRA, SR. ADVOCATE, S HRI ADITYA VOHRA, ADVOCATE AND MS. SOMYA JAIN, C.A. (AUTHORIZED REPRESENTATIVE) FOR TH E ASSESSEE, WERE IN AGREEMENT THAT THE ISSUE IN DISPUTE IS COVERED BY THE ORDER OF CO- ORDINATE BENCH OF INCOME TAX APPELLATE TRIBUNAL, DELHI (ITAT, FOR SHORT) IN AS SESSEES OWN CASE VIDE ORDER DATED 31/08/2020 IN ITA NO.- 2641/DEL/2013, IN THE CASE O F DCIT VS. MARUTI SUZUKI INDIA LTD. BOTH SIDES WERE IN AGREEMENT AT THE TIME OF HEARING BEFORE US, THAT IN IDENTICAL FACTS AND CIRCUMSTANCES, THE ISSUE HAS ALREADY BEEN DECID ED IN ASSESSEES OWN CASE, IN FAVOUR OF THE ASSESSEE, IN THE AFORESAID ORDER DATE D 31/08/2020 OF THE CO-ORDINATE BENCH OF ITAT, DELHI. OUR ATTENTION WAS ALSO DRAWN TO THE RELEVANT PORTION OF THE AFORESAID ORDER DATED 31/08/2020 OF CO-ORDINATE BEN CH OF ITAT, DELHI IN ITA NO. 2641/DEL/2013 WHICH IS REPRODUCED AS UNDER: 65. THE AO DID NOT ALLOW INTEREST TO THE ASSESSEE ON THE AMOUNTS OF TAX PAID ON 31.01.2003 AND 28.02.2003 ON THE GROUNDS THAT A FEW HOURS CANNOT BE CONSTRUTED AS PART OF A MONTH. THE AO HELD THAT IN ORDER TO QUALIFY AS PART OF THE MONTH AT LEAST ONE ENTIRE DAY SHOULD HAVE BEEN COMPLETED. ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 7 OF 10 66. THE LD. CIT(A) REFERRED TO THE ANALOGY PROVIDED U/S 234A, SEC. 234B & 234C WHEREIN SIMILAR PHRASE HAS BEEN USED. BASED O N THE PHRASEOLOGY, THE LD. CIT(A) HELD THAT WHILE INTEREST IS CHARGED FROM THE ASSESSEE WHEN THE DATE CHANGES TO THE NEXT DAY, SIMILARLY, THE ASSESSEE IS ALSO ELIGIBLE FOR RECEIPT OF INTEREST WHEN THE DATE CHANGES. HENCE, IT WAS HELD THAT THE ASSESSEE WHO PAYS TAX ON 31.01.2003 AT 23.59 HRS. AND ELIGIBLE T O REFUND OF TAX, WOULD BE ENTITLED TO INTEREST FOR THE MONTH OF JANUARY. 67. HAVING GONE THROUGH THE SPECIFIC PROVISIONS OF THE ACT, PERTAINING TO COMPUTATION OF INTEREST U/S 244A(1)(A) AND SEC. 244 A(1)(B) AS WELL AS SEC. 234A, SEC. 234B & SEC. 234C, WE HEREBY HOLD THAT TH E RULE OF COLLECTION OF INTEREST ON THE TAXES DUE FROM THE TAXPAYER WOULD B E APPLICABLE IN THE COMPARABLE WAY WHILE PAYING INTEREST TO TAXPAYER ON THE REFUND. 68. HENCE, WE HOLD THAT THE ASSESSEE IS ELIGIBLE FO R INTEREST ON THE, (I) AMOUNT OF RS. 30,00,00,000/- PAID ON 31.01.2003 IS ELIGIBLE FOR INTEREST FOR THE MONTH OF JANUARY. (II) AMOUNT OF RS. 25,00,00,000/- PAID ON 28.02.200 3 IS ELIGIBLE FOR INTEREST FOR THE MONTH OF FEBRUARY. (B.1) NEITHER SIDE HAS BROUGHT ANY MATERIALS FOR DISTING UISHING THE FACTS AND CIRCUMSTANCES OF THE CASE FOR ASSESSMENT YEARS 1995 -96, 1996-97, AND 1997-98 (TO WHICH THESES APPEALS PERTAINS) FROM FACTS AND CIRCU MSTANCES OF ASSESSMENT YEAR 1999-2000 (TO WHICH THE AFORESAID ORDER DATED 31/0 8/2020 PERTAINS). NEITHER SIDE HAS BROUGHT ANY MATERIALS FOR OUR CONSIDERATION TO PERS UADE US TO TAKE A DIFFERENT VIEW IN THESE APPEALS BEFORE US FROM THE VIEW TAKEN BY ITAT IN AFORESAID ORDER DATED 31/08/2020. NEITHER SIDE HAS BROUGHT ANY MATERIALS FOR OUR CONSIDERATION TO PERSUADE US TO INTERFERE WITH THE AFORESAID IMPUGNED APPELLA TE ORDERS DATED 29.11.2013 OF THE LD. CIT(A). IN VIEW OF THE FOREGOING; AND ON BOTH SIDES ARE AGREEMENT THAT IN IDENTICAL FACTS AND CIRCUMSTANCES THE ISSUE IN DISPUTE HAS AL READY BEEN DECIDED IN FAVOUR OF ASSESSEE IN ASSESSEES OWN CASE IN AFORESAID ORDER DATED 31/08/2020; THE APPEALS OF REVENUE VIDE ITA NOS.- 600/DEL/2014, 601/DEL/2014 A ND 602/DEL/2014 ARE DISMISSED. ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 8 OF 10 WE DIRECT THE ASSESSING OFFICER TO ALLOW INTEREST U NDER SECTION 244A OF I.T. ACT TO THE ASSESSEE TO THE ENTIRE MONTH EVEN WHEN PAYMENTS / A DJUSTMENTS WERE MADE ON THE LAST DAY OF THE MONTH. ACCORDINGLY ALL THE THREE A PPEALS FILED BY REVENUE ARE DISMISSED. (C) IN THE APPEALS FILED BY THE ASSESSEE VIDE ITA NOS. 469/DEL/2014, 470/DEL/2014 AND 471/DEL/2014 FOR ASSESSMENT YEARS 1995-96, 1996 -97 AND 1997-98 RESPECTIVELY; THE ASSESSEE HAS SOUGHT RECTIFICATION OF THE ERRORS COMMITTED BY THE ASSESSING OFFICER IN COMPUTING INTEREST UNDER SECTION 244A OF I.T. ACT. AT THE TIME OF HEARING BEFORE US, REPRESENTATIVES OF BOTH SIDES; NAMELY SHRI AJAY VOH RA, SR. ADVOCATE, SHRI ADITYA VOHRA, ADVOCATE AND MS. SOMYA JAIN, C.A. (AUTHORIZED REPRE SENTATIVE) FOR THE ASSESSEE AND MS. PARAMITA M. BISWAS, COMMISSIONER OF INCOME TAX (DEPARTMENTAL REPRESENTATIVE) FROM REVENUES SIDE WERE IN AGREEMENT THAT THE MATT ER REGARDING COMPUTATION OF INTEREST UNDER SECTION 244A OF I.T. ACT SHOULD BE R ESTORED TO THE ASSESSING OFFICER FOR FRESH COMPUTATION OF INTEREST UNDER SECTION 244A OF I.T. ACT, ALLOWABLE TO THE ASSESSEE. IN VIEW OF THE FOREGOING, AND AS BOTH SIDES HAS AGR EED TO THIS, WE RESTORE THE MATTER RAISED IN AFORESAID APPEALS OF THE ASSESSEE, TO THE FILE OF THE ASSESSING OFFICER FOR FRESH COMPUTATION OF INTEREST ALLOWABLE TO THE ASSESSEE U NDER SECTION 244A OF I.T. ACT, IN ACCORDANCE WITH LAW; AFTER PROVIDING REASONABLE OPP ORTUNITY TO THE ASSESSEE. THE AFORESAID THREE APPEALS FILED BY THE ASSESSEE VIDE ITA NOS. 469/DEL/2014, 470/DEL/2014 AND 471/DEL/2014 ARE HEREBY DISPOSED OFF WITH THIS DIRECTION. FOR STATISTICAL PURPOSES, THESE THREE APPEALS OF ASSESSEE ARE TREATED AS PART LY ALLOWED. ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 9 OF 10 (D) IN THE RESULT, APPEALS FILED BY REVENUE ARE DISMIS SED AND APPEALS FILED BY ASSESSEE ARE PARTLY ALLOWED. THE ORDER WAS ALREADY PRONOUNCED ORALLY IN THE OPEN COURT ON 17/03/2021 IN THE PRESENCE OF REPRESENTATIVES OF BOTH SIDES. NOW THI S ORDER IN WRITING IS SIGNED TODAY ON 18/03/21. SD/- SD/- (SUDHANSHU SRIVASTAVA) (ANADEE NATH MISSHRA) JUDICIAL MEMBER ACCOUNTANT MEMBE R DATED: 18/03/21 (POOJA) COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI ITA NOS.- 469/DEL/2014 AND OTHERS. MARUTI SUZUKI INDIA LTD. PAGE 10 OF 10 DATE OF DICTATION DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 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 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 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