Appeal Details
Counselvise Citation
[2018] 126 COUNSELVISE.COM (IT) 0074 (ITAT-MUMBAI)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
1 year(s) 5 month(s) 24 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
27-02-2018
Appeal Filed By
Assessee
Order Result
Partly Allowed
Bench Allotted
G
Assessment Year
2012-2013
Appeal Filed On
02-09-2016
Judgement Text
IN THE INC OME TAX APPELLATE TRIBUNAL G , BENCH MUMBAI BEFORE SHRI C. N. PRASAD , JM & DR. A.L.SAINI, AM ./ ITA NO. 5412 / MUMBAI /20 16 ( / ASSESSMENT YEAR: 2012 - 13 ) FINOTEX CHEMICALS LTD. 43/43, MANORAMA CHAMBERS, S.V. ROAD, BANDRA(WEST), MUMBAI - 400050. VS. A CIT, CIRCLE - 12(2 ), MUMBAI ./ ./ PAN/GIR NO. : AAAC F8360M (APPELLANT ) .. (RESPONDENT ) APPELLANT BY :MS. HETALMARU, FCA RE SPONDENT BY :SHRI V. VIDHYADGAV , DR / DATE OF HEARING : 20 /02 /201 8 / DATE OF PRONOUNCEMENT : 27 /02/2018 / O R D E R PER DR. ARJUNLALSAINI, AM: THE CAPTIONED APPEAL FILED BY THE A SSESSEE , PE RTAINING TO ASSESSMENT YEAR 2012 - 13 , IS DIRECTED AGAINST AN ORDER PASSED BY THE COMMISSIONER OF INCOME TAX - (APPEALS) - 20 , MUMBAI , IN APPEAL NO.CIT(A) - 20 / ACIT - 12(2)(1)/ IT - 19/2015 - 16 , DATED 27.05 .2016 , WHICH IN TURN ARISES OUT OF AN ORDER PASSED BY THE ASSESSING OFFICER U/S 143(3) OF THE INCOME TAX ACT, 1961 (HEREINAFTER REFERRED TO AS THE ACT) . 2 . GROUND NO.1 RAISED BY THE A SSESSEE RELATES TO DISALLOWANCE UNDER SECTION 14A READ WITH R ULE 8D(2)(III) AT RS.6,36,960/ - . FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 2 2 .1 THE BRIEF FACTS APROPOS THIS ISSUE ARE THAT WHILE MAKING ASSESSMENT U/S 143(3) OF THE ACT, THE A SSESSING O FFICER NOTICED THAT THE ASSESSEE HAS EARNED A DIVIDEND INCOME OF RS.14,79,630/ - IN THE ASSESSMENT YEAR UNDER CONSIDERATION. AT THE SAME TIME, THE ASSESSEE HAS C LAIMED INTEREST EXPENSES OF RS.29,09,739/ - . THE ASSESSEE HAS SHOWN NON - CURRENT INVESTMENTS AT RS.8,38,68,940/ - AND INVESTMENTS OF RS.1 9 ,57,15,948/ - IN ITS BALANCE SHEET AS ON 31.03.2012. DURING THE ASSESSMENT PROCEEDINGS, THE ASSESSEE WAS ASKED TO JUSTIFY ITS CLAIM OF VARIOUS EXPENSE ,AS PER THE PROVISIONS OF SECTION 14A R.W.R 8D OF THE INCOME TAX ACT, 1962, IN ITS P ROFIT &L OSS ACCOUNT . IN RESPONSE TO THAT, THE ASSESSEE SUBMITTED ITS REPLY ON 26.02.2015. AFTER GOING THROUGH THE REPLY OF THE ASSESSEE, THE AO FOUND THAT ASSESSEE HAS INCURRED EXPENDITURE IN RELATION TO EAR NING OF EXEMPT INCOME , T HEREFORE, PROVISIONS OF SECTION 14A R.W.R 8D WOULD BE APPLICABLE. THE ASSESSING OFFICER NOTED THAT FOR THE PURPOSE OF APPLICABILITY OF SECTION 14A, IT IS NOT NECESSARY T HAT THE ASSESSEE SHOULD HAVE ACTUALLY EARNED EXEMPT INCOME DURING THE YEAR. ALL THE INCOME FROM INVESTMENTS WHI CH DOES NOT OR SHALL NOT FORM PART OF TOTAL INCOME ARE TO BE INCLUDED FOR WORKING OUT THIS DISALLOWANCE. THIS WAY, THE ASSESSING OFFICER , CONSIDE RING ALL THE INVESTMENTS , CONSISTING FUNDS GENERATING EXEMPT INCOME AND FUNDS NOT GENERATING EXEMPT INCOME, WORKED OUT DISALLOWANCE AS PER RULE 8D(2)(III) , WHICH IS GIVEN BELOW: OPENING BALANCE OF INVESTMENTS AS ON 31.03.2011 5,90,67,943/ - CLOSING BALANCE OF INVESTMENTS AS ON 31.03.2012 19,57,15,948/ - AVERAGE VALUE OF INVESTMENTS 12,73,91,946/ - DISALLOWANCE AS PER RULE 8D(III) BEING 0.5% OF AVERAGE INVESTMENTS RS.6,36,960/ - THEREFORE, THE AO HAS DISALLOWED RS.6,36,960/ - U/S 14A R.W.R 8D OF THE INCOME TAX ACT, 1962. 2 .2 ON APPEAL, THE LD. CIT(A) HAS CONFIRMED THE DISALLOWANCE MADE BY THE ASSESSING OFFICER U/S 14A READ WITH RULE 8D(2)(III) OF THE ACT. THE LD. CIT(A) OBSERVED THAT A COMPANY CANNOT EARN DIVIDEND INCOME WITHOUT ITS EXISTENCE AND MANAGEMENT, THEREFORE, SOME EXPENSES MUST HAVE INCURRED BY THE ASSESSEE , IN ORDER TO TAKE THE INVESTMENTS FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 3 DECISIONS. THEREFORE, CIT(A) HELD THAT THE AO HAD CORRECT LY APPLIED RULE 8D (2) (III) AND WORKED DISALLOWANCE U/S 14A OF THE ACT TO THE TUNE OF RS.6,36,960/ - . 2 .3 NOT BEING SATISFIED WITH THE ORDER O F THE LD. CIT(A), THE ASSESSEE IS IN FURTHER APPEAL BEFORE US. THE LD. COUNSEL FOR THE ASSESSEE SUBMITTED BEFORE US THAT ASSESSEE - COMPANY HAS NOT INCURRED ANY EXPENSES IN RELATION TO E ARNING OF EXEMPT INCOME. THE COUNSEL POINTED OUT THAT A FINANCIAL ADVISOR WAS APPOINTED BY THE MUTUAL FUND AND THE SAID FINANCIAL ADVISOR IS PAID COMMISSION BY THE MUTUAL FUND DIRECTLY THEREFORE, COMPANY IS NOT INCURR ING ANY EXPENDITURE TO MAINTAIN THE IN VESTMENTS AND TO TAKE THE DAY TO DAY DECISIONS ABOUT SALE AND PURCHASE OF INVESTMENTS . THE LD. COUNSEL FOR THE ASSESSEE ALSO POINTED OUT THAT THE AO WAS ERRED IN TAKING INTO ACCOUNT THE FUNDS WHICH WERE NOT GENERATING EXEMPT INCOME, THAT IS , THE FUNDS WHIC H WERE NOT GENERAT ING EXEMPT INCOME SHOULD NOT BE CONSIDERED FOR THE PURPOSE OF DISALLOWANCE UNDER RULE 8D(2)(III). THE LD. COUNSEL SUBMITTED BEFORE US, THE DETAILS OF FUNDS GENERATING EXEMPT INCOME AND FUNDS NOT GENERATING EXEMPT INCOME, AND, ALSO SUBMITT ED THE OPENING AND CLOSING BALANCE AS ON 31.03.2011 AND 31.03.2012 WHICH ARE GIVEN BELOW: DETAILS OF MUTUAL FUNDS AS ON 31 ST MARCH 2011 OPENING INVESTMENTS SL. NO. PARTICULARS AMOUNT (RS.) A FUNDS GENERATING EXEMPT INCOME I. DEBT ORIENTED MUTUAL FUNDS 1 KOTAK CREDIT OPPORTUNITIES FUND 51,50,436 II EQUITY ORIENTED MUTUAL FUNDS 1 BIRLA SUNLIFE DIVIDEND YIELD PLUS - GROWTH 20,82,612 2 HDFC EQUITY FUND GROWTH 17,35,230 3 KOTAK MID CAP GROWTH 4,67,226 4 PRAMERICA DYNAMIC FUND GROWTH 29,34,000 5 RELIANCE GROWTH FUND RETAIL PLAN 3,50,123 SUNDARAM SELECT MIDCAP APPRECIATION FUND 20,02,717 TOTAL(A) 1,47,22,343 B FUNDS NOT GENERATING EXEMPT INCOME I. DEBT ORIENTED MUTUAL FUNDS 1 BIRLA SUNLIFE CASH MANAGER GROWTH 1,50,50,418 2 BIRLA SUN LIFE CAPITAL PROTECTION ORIENTED FUND 30,00,000 FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 4 SERIES 1 GROWTH 3 BIRLA SUN LIFE MONTHLY INCOME - GROWTH 41,76,261 4 DWS SHORT MATURITY FUND - GROWTH PLAN 40,00,000 5 HDFC CASH MANAGEMENT FUND - TREASURY ADVANTAGE RETAIL GROWTH 1,50,49,917 RELIANCE REGULAR SAVINGS FUND DEBT PLAN - GROWTH FUND 30,69,004 TOTAL(B) 4,43,45,600 TOTAL MUTUAL FUNDS (A+B) 5,90,67,943/ - DETAILS OF MUTUAL FUNDS AS ON 31 ST MARCH 2012 CLOSING INVESTMENTS SL. NO. PARTICULARS AMOUNT (RS.) A FUNDS GENERATING EXEMPT INCOME I. EQUITY ORIENTED MUTUAL FUNDS 1 BIRLA SUNLIFE DIVIDEND YIELD PLUS GROWTH 63,00,000 2 HDFC EQUITY FUND - GROWTH 58,58,590 3 ICICI PRUDENTIAL FOCUSED BLUECHIP EQUITY RETAIL GROWTH 25,00,000 4 KOTAK MID CAP - GROWTH 4,69,849 5 PRAMERICA DYNAMIC FUND - GROWTH 27,54,000 6 RELIANCE GROWTH FUND RETAIL PLAN 3,16,839 7 SUNDARAM SELECT MIDCAP APPRECIATION FUND 58,55,473 TOTAL(A) 2,40,54,751/ - B FUNDS NOT GENERATING EXEMPT INCOME II. DEBT ORIENTED MUTUAL FUNDS 1 BIRLA SUNLIFE CASH MANAGER WEEKLY DIVIDEND - GROWTH 3,32,86,845 2 BNP PARIBAS BOND FUND (349610/31) - REGULAR GROWTH 25,00,000 3 BNP PARIBAS BOND FUND (349611/28) - REGULAR GROWTH 70,00,000 4 BIRLA SUN LIFE CAPITAL PROTECTION ORIENTED FUND SERIES 1 GROWTH 30,00,000 5 DWS PREMIER BOND FUND - REGULAR PLAN GROWTH 20,00,000 6 DWS SHORT MATURITY FUND - GROWTH PLAN 22,84,544 7 HDFC CASH MANAGEMENT FUND - TREASURY ADVANTAGE RETAIL GROWTH 5,16,80,076 8 ICICI PRUDENTIAL REGULAR SAVINGS FUND GROWTH 95,00,000 9 KOTAK BOND (REGULAR) GROWTH 2016612/54 55,00,000 10 KOTAK CREDIT OPPORTUNITIES FUND GROWTH 54,09,733 11 SBI DYNAMIC BOND FUND 13424221 - GROWTH 15,00,000 12 UTI BOND FUND GROWTH PLAN REGULAR 80,00,000 13 UTI TREASURE ADVANTAGE FUND GROWTH PLAN 4,00,00,000 TOTAL(B) 17,16,61,197 TOTAL (A+B) 19,57,15,948 THE LD. COUNSEL FOR THE ASSESSEE, THEREAFTER, CONTENDED THAT IN ANY EVENT , IF ANY DISALLOWANCE IS TO BE MADE UNDER RULE 8D(2)(III) , THEN IT SHOULD BE IN RELATION TO FUNDS GENERATING EXEMPT INCOME. BASED ON THE FUNDS GENERATING EXEMPT INCOME, THE COUNSEL SUBMITTED BEFORE US THAT THE DISALLOWANCE U/S 14A R.W.R 8D(2)(III) VIS - - VIS THE DISALLOWANCE FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 5 MADE BY THE AO IN HIS ASSESSMENT ORDER ARE ANALYZED AND COMPARED , WHICH ARE GIVEN BELOW : DISALLOWANCE U/S.14A SN PARTICULARS AS PER ASSESSING OFFICER AS PER APPELLANT AMOUNT (RS.) AMOUNT (RS.) AMOUNT (RS.) AMOUNT (RS.) I. RULE 8D(I) DIRECT EXPENSES - - II. RULE 8D(II) INTEREST EXPENSES - - III. RULE 8D(III) ADMINISTRATIVE EXPENSES OPENING BALANCE OF INVESTMENT AS ON 31 ST MARCH, 2011 5,90,67,943 1,47,22,343 CLOSING BALANCE OF INVESTMENT AS ON 31 ST MARCH, 2012 19,57,15,948 2,40,54,751 AVERAGE INVESTMENT 12,73,91,946 1,93,88,547 0.5% OF AVERAGE INVESTMENT RULE 8D(III) DISALLOWANCE 6,36,960 96,943 TOTAL DISALLOWANCE UNDER RULE 8D(I+II+III) 6,36,960 96,943 T HE LD. COUNSEL SUBMITTED BEFORE US THAT TOTAL DISALLOWANCE UNDER RULE 8D (2) (III) SHOULD BE ONLY TO THE TUNE OF RS. 96,943/ - , AS COMPUTED IN THE ABOVE TABLE WHICH IS BASED ON THOSE FUNDS WHICH GENERATE EXEMPT INCOME. THE FUNDS WHICH DO NOT GENERATE EXEMPT INCOME SHOULD NOT BE CONSIDERED IN COMPUTING THE DISALLOWANCE UNDER RULE 8D (2) (III), THEREFORE, THE ASSESSING OFFICER WAS ERRED IN TAKING INTO ACCOUNT THOS E FUNDS WHICH ARE NOT GENERATING EXEMPT INCOME. HENCE , THE DISALLOWANCE , IF ANY, TO BE MADE, SHOULD BE IN RELATION TO THE FUNDS GENERATING EXEMPT INCOME . 2.4 ON THE OTHER HAND, THE LD. DR FOR THE R EVENUE HAS PRIMARILY REITERATED THE STAND TAKEN BY THE ASSE SSING OFFICER WHICH WE HAVE ALREADY NOTED IN OUR EARLIER PARA AND IS NOT BEING REPEATED FOR THE SAKE OF BREVITY. 2.5 WE HAVE GIVEN A CAREFUL CONSIDERATION TO THE RIVAL SUBMISSIONS, AND PERUSED THE MATERIALS AVAILABLE ON RECORD, WE NOTE THAT THE DISALLOWANCE U/S 14A R.W.R8D(2)(III) SHO U LD BE IN RELATION TO FUNDS GENERATING EXEMPT INCOME ONLY . IN RESPECT OF PROVISIONS OF RULE 8D(2)(III), WHICH IS THE SUBJECT MATTER OF THE APPEAL IN THE ASSESSEES FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 6 CASE UNDER CONSIDERATION, A PERUSAL OF THE SAID PROV ISION SHOWS THAT WHAT IS DISALLOWABLE UNDER RULE 8D(2)(III) IS THE AMOUNT EQUAL TO % OF THE AVERAGE VALUE OF INVESTMENT, THE INCOME FROM WHICH DOES NOT AND SHALL NOT FORM PART OF THE TOTAL INCOME. THUS, UNDER RULE 8D(2)(III) WHAT IS DISALLOWABLE IS % OF THE DIVIDEND BEARING SECURITIES OR FUNDS GENERATING EXEMPT INCOME. THEREFORE, NOT ALL INVESTMENTS BECOME THE SUBJECT MATTER OF CONSIDERATION WHILE COMPUTING DISALLOWANCE U/S 14A R.W RULE 8D(2)(III). THE DISALLOWANCE U/S 14A R.W.RULE 8D(2)(III) IS TO BE IN RELATION TO THE INCOME WHICH DOES NOT FORM PART OF THE TOTAL INCOME AND THIS CAN BE DONE ONLY BY TAKING INTO CONSIDERATION THE INVESTMENTS WHICH HAS GIVEN RISE TO THIS INCOME WHICH DOES NOT FORM PART OF THE TOTAL INCOME. WE NOTE THAT A S FAR AS RULE 8D(2)( III) OF THE RULES IS CONCERNED , IT HAS BEEN HELD BY THE HONBLE ITAT KOLKATA BENCH IN THE CASE OF DCIT VS REI AGRO LTD. IN ITA NO.1811/KOL/2012 DATED 14.05.2013 THAT IT IS ONLY THE INVESTMENT WHICH YIELDED TAX FREE INCOME THAT SHOULD BE CONSIDERED FOR WORK ING OUT THE AVERAGE VALUE OF INVESTMENT WHILE APPLYING THE RULE 8D(2)(III) OF THE RULES. THIS ORDER OF THE TRIBUNAL HAS BEEN CONFIRMED BY THE DECISION OF HONBLE CALCUTTA HIGH COURT IN G.A. NO.3022 OF 2013 JUDGEMENT DATED 23.12.2013. IN VIEW OF THE AFORES AID LEGAL POSITION WE ARE OF THE VIEW THAT THE ORDER OF THE CIT(A) ON THIS ISSUE CANNOT BE SUSTAINED. IT HAS ALSO BEEN HELD BY THE HONBLE DELHI HIGH COURT IN THE CASE OF CHEMINVEST LTD VS CIT (2015) 378 ITR 33 (DEL) THAT WHEN THERE IS NO EXEMPT INCOME TH EN THERE CAN BE NO QUESTION OF DISALLOWANCE U/S 14A OF THE ACT. IN THE LIGHT OF THE JUDICIAL PRONOUNCEMENTS, WE ARE OF THE VIEW THAT THE PLEA OF THE ASSESSEE TO EXCLUDE FUNDS WHICH ARE NOT GENERATING EXEMPT INCOME, THAT IS, WHICH HAD NOT YIELDED ANY EXEMPT DIVIDEND INCOME DURING THE PREVIOUS YEAR WHILE WORKING OUT THE AVERAGE VALUE OF INVESTMENTS FOR THE PURPOSE OF APPLYING RULE 8D(2)(III) OF THE RULES, SHOULD BE ACCEPTED. FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 7 HOWEVER, WE DO NOT ACCEPT THE PLEA OF THE ASSESSEE T HAT COMMISSION OF FINANCIAL ADVISOR WAS PAID BY THE MUTUAL FUND DIRECTLY THEREFORE NO ANY EXPENSES HAVE BEEN INCURRED BY THE COMPANY TO MAINTAIN THE INVESTMENT PORTFOLIO. ULTIMATELY, THE DIRECTORS OF THE COMPANY OR TOP MANAGEMENT INSTRUCTS THE FINANCIAL AD VISOR , ABOUT HOW MUCH INVESTMENT IS TO BE DONE, HOW MUCH IS TO BE SOLD OR RETAINED. CONSIDERING THE RATIO OF ABOVE CITED JUDGMENT S OF COORDINATE BENCH OF ITAT KOLKATA AND HON' BLE KOLKATA HIGH COURT (SUPRA), WE RESTORE THE PRESENT ISSUE TO THE FILE OF THE A SSESSING OFFICER FOR COMPUTATION OF DISALLOWANCE U/S 14A R.W. RULE 8D(2)(III) AND WE DIRECT THE ASSESSING OFFICER TO CONSIDER ONLY FUNDS GENERATING EXEMPT INCOME TO COMPUTE THE DISALLOWANCE UNDER RULE 8D(2)(III) OF THE I.T.RULES. 2.6 IN THE RESULT, THE AP PEAL FILED BY THE ASSESSEE ( GROUND NO.2), IS ALLOWED FOR STATISTICAL PURPOSES. 3 . GROUND NO.3 RAISED BY THE ASSESSEE RELATES TO ADDITION OF INCOME OF RS.25,000/ - MADE BY THE AO UNDER THE HEAD OF PROFIT AND GAINS OF BUSINESS OR PROFESSION, WHILE COMPUTING THE TAX LIABILITY. T HE LD. COUNSEL FOR THE ASSESSEE POINTED OUT THAT ASSESSING OFFICER, WHILE GOING THROUGH THE INCOME - TAX COMPUTATION FORM , HAS TAKEN THE AMOUNT OF RS.7,15,07,112/ - AS PROFIT AND GAINS OF BUSINESS OR PROFESSION. HOWEVER, IN THE ASSESSME NT ORDER, THE AO AFTER MAKING DISALLOWANCE U/S 14A HAS CORRECTLY COMPUTED INCOME UNDER THE HEAD PROFIT AND GAINS OF BUSINESS OR PROFESSION AT RS.7,0 8 ,45,144/ - , THEREFORE, THE DIFFERENCE OF RS.25,008/ - IS TO BE RECTIFIED AS PER THE ASSESSEE`S RECONCILIATI ON GIVEN BELOW: ( I ) INCOME - TAX COMPUTATION: 7,15,07,112/ - (II) AOS ORDER AFTER TAKING DISALLOWANCE U/S 14A: 7,09,45,144// - FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 8 BALANCE 76,19,68/ - LESS: DISALLOWANCE U/S 14A: 63,69,60/ - BALANC E DIFFERENCE 25,008/ - THEREFORE, THE LD. COUNSEL FOR THE ASSESSEE REQUESTED THE BENCH TO DIRECT THE AO TO CORRECT TYPOGRAPHICAL ERROR. HAVING GONE THROUGH THE FACTS AND FIGURES EXPLAINED ABOVE, WE NOTE THAT AN ARITHMETIC ERROR COMMITTED BY THE ASSESSING OFFICER TO THE TUNE OF RS .25,008/ - NEEDS TO BE RECTIFIED. THEREFORE, WE DIRECT THE AO TO EXAMINE THE FIGURES AND FACTS REFERRED ABOVE AND RECTIFY THE MISTAKE AS PER PROVISIONS OF LAW. 3 .1 IN THE RESULT, GROUND NO.3 RAISED BY THE ASSESSEE IS ALLOWED FOR STATISTICAL PURPOSES. ORDER IS PRONOUNC ED IN THE OPEN COURT ON 27 .02.2018 . SD/ - ( C. N. PRASAD ) SD/ - (DR. A.L.SAINI) / JUDICIAL MEMBER / ACCOUNTANT MEMBER PLACE: MUMBAI DATED 27 /02/2018 ( RS , S PS ) / COPY OF THE ORDER FORWARDED TO : TRUE COPY BY ORDER ASSISTANT REGISTRAR , I.T.A.T, MUMBAI BENCHES, MUMBAI . 1. / THE APPELLANT FINOTEX CHEMICALS LTD. 2. / THE RESPONDENT - ACIT, CIRCLE - 12(2), MUMBAI 3. ( ) / THE CIT(A), 4. / CIT 5. DR, ITAT, 6. / GUARD FILE. FINOTEX CHEMICALS LTD. ITA NO.5412/MUMBAI/2016 PAGE | 9 SL. NO. DETAILS DATE INITIALS DESIGNATION 1 DRAFT DICTATED ON 20.02.2018 SR.PS/PS 2 DRAFT PLACED BEFORE AUTHOR 22.02.2018 SR.PS/PS 3 DRAFT PROPOSED& PLACED BEFORE THE SECOND MEMBER JM/AM 4 DRAFT DISCUSSED/APPROVED BY SECOND MEMBER JM/AM 5 APPROVED DRAFT COMES TO THE SR. PS/PS SR.PS/PS 6 KEPT FOR PRONOUNCEMENT SR.PS/PS 7 FILE SENT TO BENCH CLERK SR.PS/PS 8 DATE ON WHICH THE FILE GOES TO HEAD CLERK 9 DATE ON WHICH FILE GOES TO A.R 10 DATE OF DISPATCH OF ORDER DICTATION PAD ATTACHED
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