M/s. Akzo Nobel India Ltd., Gurgaon V. Addl. CIT, New Delhi

ITA 6007/DEL/2014

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 6612 (ITAT-DELHI)
• Duration Of Justice: 3 year(s) 8 month(s) 18 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-07-2018
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: I
• Assessment Year: 2008-2009
• Appeal Filed On: 05-11-2014
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: SANJAY I BARA
• Keywords: Transfer pricing; International transaction; Wholly owned subsidiary; Deemed dividend
• Section: 143(3); 92D; 234B

Judgement Text

1 ITA NO. 6144 & 6007/DEL/2014 ITA IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: I-1 NEW DELHI BEFORE SHRI N. K. SAINI, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDI CIAL MEMBER ITA NO. 6144/DEL/201 4 ( A.Y 2008-09) DCIT CIRCLE-1(1) NEW DELHI (APPELLANT) VS AKZO NOBLE CAR REFINISHES INDIA PVT. LTD. PLOT 62P, HOSKOTE INDUSTRIAL AREA BANGALORE 562114 (RESPONDENT) ITA NO. 6007/DEL/2014 ( A.Y 2008-09) AKZO NOBLE INDIA LTD. (FORMERLY KNOWN AS AKZO NOBEL CAR REFINISHES INDIA PVT. LTD.) GEETANJALI APARTMENT, 1 ST FLOOR 8- B, MIDDLETON STREET, KOLKATA-700 071 (APPELLANT) VS THE ADDITIONAL COMMISSIONER OF INCOME TAX CIRCLE-1(1), NEW DELHI (RESPONDENT) APPELLANT BY SH. VISHAL KALRA, ADV , MS. REEMA MALIK, CA RESPONDENT BY SH. SANJAY I. BARA, CIT DR ORDER PER SUCHITRA KAMBLE, JM THESE APPEALS ARE FILED BY THE ASSESSEE AS WELL AS BY THE REVENUE AGAINST THE ASSESSMENT ORDER DATED 07.02.2012 PASSED BY THE ASSESSING OFFICER U/S 143 (3) READ WITH SECTION 144C OF THE INCOME TAX AC T, 1961. DATE OF HEARING 02.07.2018 DATE OF PRONOUNCEMENT 24.07.2018 2 ITA NO. 6144 & 6007/DEL/2014 ITA 2. THE GROUNDS OF APPEAL ARE AS UNDER:- ITA NO. 6144/DEL/2014 1. ON THE FACTS AND IN THE CIRCUMSTANCES OF THE CAS E, THE LD.CIT(A) HAS ERRED IN DELETING THE ADDITION MADE BY THE A.O AT R S.6,00,00,000/- ON ACCOUNT OF DEEMED DIVIDEND AND RS.8,74,517/- AS INT EREST THEREON BY HOLDING THAT THE ASSESSEE WAS NOT A SHAREHOLDER OF THE PAY ER COMPANY WHEN THE A.O HAD CLEARLY ESTABLISHED THAT THE PAYER COMPANY WAS DE FACTO BENEFICIAL SHAREHOLDER OF THE ASSESSEE. ITA NO. 6007/DEL/2014 1. THAT THE LEARNED COMMISSIONER OF INCOME TAX (A PPEALS) - XX, DELHI [CIT (APPEALS)] ERRED IN DISREGARDING THE TRANSFER PRIC ING (TP) DOCUMENTATION AND THEREBY ERRED IN NOT APPRECIATING ECONOMIC ANALYSIS CONDUCTED BONAFIDE BY THE APPELLANT IN RESPECT OF ITS CONTRACT RESEARCH A ND DEVELOPMENT SERVICES (R&D SEGMENT), PERFORMED WITH DUE DILIGENCE AND U SING THE DATA AVAILABLE AT THE TIME OF CONDUCTING THE COMPARABILITY ANALYSI S. 2. THE LEARNED CIT (APPEALS) ERRED ON FACTS AND CI RCUMSTANCES OF THE CASE AND IN LAW BY CONFIRMING AN TRANSFER PRICING ADJUST MENT AMOUNTING TO INR 26,850,486 HOLDING THAT THE INTERNATIONAL TRANSACTI ON PERTAINING TO CONTRACT R&D SEGMENT DO NOT SATISFY THE ARMS LENGTH PRINCIP LE ENVISAGED UNDER THE ACT AND IN DOING SO HAVE GROSSLY ERRED IN: 2.1. NOT APPRECIATING THAT THE APPELLANT HAD PREPAR ED THE TRANSFER PRICING DOCUMENTATION BONA FIDE AND IN GOOD FAITH IN COMPLI ANCE WITH THE PROVISIONS OF SECTION 92D OF THE ACT READ WITH RULE XOD OF THE INCOME TAX RULES, 1962 (RULES) AND SELECTED UNCONTROLLED COMPARABLE COMP ANIES BASED ON A DETAILED FUNCTIONAL, ASSET AND RISK (FAR) ANALYSIS, FOLLOW ING A METHODICAL AND CONSISTENT BENCHMARKING PROCESS IN RESPECT OF CONTR ACT RESEARCH AND DEVELOPMENT SERVICES. 2.2. REJECTING THE ARMS LENGTH MARGIN COMPUTED BY THE APPELLANT FOR CONTRACT R&D SERVICE SEGMENT USING MULTIPLE YEAR / AVERAGE DATA AND 3 ITA NO. 6144 & 6007/DEL/2014 ITA INSTEAD USING CURRENT YEAR DATA FOR COMPARABLE COMP ANIES, I.E., DATA FOR FINANCIAL YEAR 2007-08, DESPITE THE FACT THAT THE S AME WAS NOT AVAILABLE WITH THE APPELLANT AT THE TIME OF PREPARING ITS TRA NSFER PRICING DOCUMENTATION. 2.3. IGNORING THE COMPARABILITY ANALYSIS UNDERTAKE N BY THE APPELLANT FOR ITS CONTRACT R&D SERVICES AND THEREBY PERFORMING HI S OWN COMPARABILITY ANALYSIS IN MAKING ADJUSTMENT TO THE TRANSFER PRICE OF THE APPELLANT. 2.4. CONSIDERING ONLY ONE COMPARABLE COMPANY NAMEL Y TCG LIFESCIENCES LIMITED TO BENCHMARK THE INTERNATIONAL TRANSACTION PERTAINING TO CONTRACT R&D SEGMENT THEREBY EXPECTING THE APPELLANT TO PERFORM AT PAR WITH TCG LIFESCIENCES LIMITED AND ALSO DISREGARDING THE STAT ISTICAL PRINCIPLE WHICH STATES THAT OTHER THINGS BEING EQUAL, AS THE SAMPL E SIZE INCREASES, THE RESULTS TEND TO BE MORE RELIABLE AND ACCURATE. 2.5 IGNORING THE LIMITED RISK NATURE OF THE CONTR ACT R&D SERVICES PROVIDED BY THE APPELLANT AND IN NOT PROVIDING AN APPROPRIATE A DJUSTMENT TOWARDS THE RISK DIFFERENTIAL. 2.6. NOT APPRECIATING THE FACT THAT THERE ARE SIG NIFICANT DIFFERENCES IN THE LEVELS OF WORKING CAPITAL EMPLOYED BY THE COMPARABL ES VIS-A-VIS THAT OF THE APPELLANT AND SUITABLE ADJUSTMENT FOR DIFFERENCES I N WORKING CAPITAL NEEDS TO BE PROVIDED. 2.7. DENYING THE BENEFIT OF (+/-) 5% RANGE MENTION ED IN THE PROVISO TO SECTION 92C(2) OF THE ACT IN DETERMINATION OF THE A RMS LENGTH PRICE. 3. THE LEARNED CIT (APPEALS) ERRED IN CONSIDERI NG THE PAYMENT OF INR 19,465,250 BY THE APPELLANT TOWARDS THE ADMINISTRAT IVE SERVICES RECEIVED FROM THE ASSOCIATED ENTERPRISES (AES) TO BE NIL , AND IN DOING SO GROSSLY ERRED IN LAW AND IN FACTS FOR THE FOLLOWING REASONS : 3.1. APPLYING THE COMPARABLE UNCONTROLLED PRICE M ETHOD AND REJECTING THE APPLICATION OF TRANSACTIONAL NET MARGIN METHOD AS M OST APPROPRIATE METHOD FOR DETERMINATION OF ARMS LENGTH PRICE IN CASE OF PAYMENT OF ADMINISTRATION FEE. 3.2. DRAWING CONCLUSION AS REGARDS TO NO ECONOMIC VALUE WAS DERIVED AND THAT NO TANGIBLE AND SUBSTANTIAL COMMERCIAL BENEFIT WAS DERIVED OUT OF SERVICES FOR WHICH THE ADMIN FEE WAS PAID. 3.3. DISREGARDING THE COLLECTIVE EVIDENCES PROVID ED IN JUSTIFICATION OF THE 4 ITA NO. 6144 & 6007/DEL/2014 ITA ARMS LENGTH NATURE OF INTERNATIONAL TRANSACTIONS P ERTAINING TO THE PAYMENT OF ADMINISTRATION FEE. 3.4 THE SUPPORT SERVICES ARE IN THE NATURE OF ST EWARDSHIP AS IT RESULT INTO BENEFIT TO THE AES AND SUCH COORDINATION ACTIVITY I S REQUIRED TO BE CARRIED OUT BY THE PARENT COMPANIES TO IMPROVE ITS GLOBAL PRESE NCE AND GLOBAL PROFIT. 4. THE LEARNED CIT (APPEALS) ERRED IN UPHOLDING THE CHARGING OF INTEREST UNDER SECTION 234B OF THE ACT. 5. THAT THE APPELLANT CRAVES LEAVE TO ADD TO AND / OR ALTER, AMEND, RESCIND OR MODIFY THE GROUNDS TAKEN HEREINABOVE BEFORE OR A T THE TIME OF HEARING OF THIS APPEAL. 3. AKZO NOBEL CAR REFINISHES INDIA PRIVATE LIM ITED IS A WHOLLY OWNED SUBSIDIARY OF AKZO NOBEL COATINGS INTERNATIONAL BV, NETHERLANDS. THE COMPANY WAS INCORPORATED ON DECEMBER 05, 1997. THE ASSESSEE IS ENGAGED IN THE BUSINESS OF DISTRIBUTION OF CAR REFINISH PAINTS AND ANCILLARIES IN INDIA AND PROVIDING RESEARCH AND DEVELOPMENT SERVICES TO ITS GLOBAL AFFILIATES AS CONTRACT SERVICE PROVIDER BEING REMUNERATED ON THE BASIS OF A MARK-UP ON TOTAL COST OF 5%. THE TPO HAS DETERMINED THE FOLLOWING TP ADJUSTM ENTS: PARTICULARS OUTCOME OF TP ORDER RECEIPTS TOWARDS CONTRACT RESEARCH AND DEVELOPMENT SERVICES ADJUSTMENT OF RS. 26,850,486 ADMINISTRATION FEES PAID ADJUSTMENT OF RS. 19,465,250 THE ASSESSEE COMPANY FILED ITS RETURN ON 30/9/2008 FOR THE ASSESSMENT YEAR 2008-09 DECLARING LOSS OF INCOME AT RS.22,87,532/-. VARIOUS ADDITIONS ON ACCOUNT OF TRANSFER PRICING, DEEMED DIVIDEND U/S 2( 22) (E) AND INTEREST PAID ON LOAN HELD TO BE DEEMED DIVIDEND U/S 2(22) (E) WE RE EFFECTED IN THE ASSESSMENT ORDER, THE SAME ARE AS FOLLOWS: PARTICULARS AMOUNT (INR) TOTAL INCOME AS PER RETURN A (22,87,532) 5 ITA NO. 6144 & 6007/DEL/2014 ITA ADD: 1) ADDITION ON ACCOUNT OF DEEMED DIVIDEND B 6,08,74,517 2) ADDITION UNDER SECTION 92CA OF THE ACT C 4,63,15,736 TOTAL INCOME ASSESSED UNDER SECTION 143(3) OF THE ACT D=A+B+C 10,49,02,721 4. BEING AGGRIEVED BY THE ASSESSMENT ORDER, THE ASS ESSEE FILED APPEAL BEFORE THE CIT(A). THE CIT(A) PARTLY ALLOWED THE AP PEAL OF THE ASSESSEE. AGGRIEVED BY THE ORDER OF THE CIT(A), THE REVENUE A S WELL AS THE ASSESSEE ARE BEFORE US. 5. DURING THE HEARING THE LD. AR SUBMITTED THAT THE HONBLE KARNATAKA HIGH COURT VIDE DECREE DATED 15/12/2014 HAS CONCLUD ED THE AMALGAMATION W.E.F 1 ST APRIL 2011 THE SAME INFORMATION WAS AVAILABLE BEFO RE THE TRANSFER PRICING OFFICER AS WELL AS BEFORE THE ASSESSING OFF ICER. THUS, THE LD. AR HAS TAKEN PRIMA FACIE LEGAL GROUND THAT THE ASSESSING O FFICER PASSED ASSESSMENT ORDER ON A NON EXISTING ENTITY. THUS, THE REVENUE S APPEAL IS ON NON EXISTING ENTITY AND IS NOT MAINTAINABLE. THE LD. DR COULD NO T CONTROVERT THIS POSITION. 6. WE HAVE HEARD BOTH THE PARTIES IN RESPECT OF THE REVENUES APPEAL. IT IS PERTINENT TO NOTE THAT THE REVENUE WAS VERY WELL IN FORMED BY THE ASSESSEE ABOUT THE NON EXISTENCE OF THE ENTITY NAMED M/S. AK ZO NOBLE CAR REFINISHES INDIA PVT. LTD. THUS, THE APPEAL IS NOT MAINTAINABL E IN RESPECT OF THE NON- EXISTING ENTITY. THEREFORE, REVENUES APPEAL IS DIS MISSED. 7. IN RESULT, APPEAL OF THE REVENUE IS DISMISSED. 6 ITA NO. 6144 & 6007/DEL/2014 ITA 8. AS REGARDS TO THE ASSESSEES APPEAL, THE LD. AR SUBMITTED THAT THE TRIBUNAL IN ASSESSEES OWN CASE FOR A.Y. 2007-08 BE ING ITA NO. 2936 & 3005/DEL/2014 ORDER DATED 08.01.2018 HAS PARTLY ALL OWED THE APPEAL OF THE ASSESSEE WHEREIN THE IDENTICAL ISSUES WERE CONTESTE D BY THE REVENUE AS WELL AS BY THE ASSESSEE. THE LD. DR RELIED UPON THE ASSESSM ENT ORDER BUT COULD NOT CONTROVERT THE EARLIER ASSESSMENT YEAR DECISION OF THE TRIBUNAL. 9. WE HAVE HEARD BOTH THE PARTIES AND PERUSED ALL T HE RELEVANT RECORDS. THE TRIBUNAL IN A.Y. 2007-08 WHEREIN THE SAME COMPARABL ES HAVE BEEN CONTESTED DIRECTED THE TPO/AO TO EXCLUDE THESE COMPARABLES. T HE TRIBUNAL HELD AS UNDER: 13. AS RELATES TO THE ASSESSEES APPEAL, THE LD. A R SUBMITTED THAT THE ASSESSEE IS ENGAGED IN SALE AND DISTRIBUTION OF CAR REFINISHES AND CONTRACT (R &D) WHICH IS ENGAGED IN AUTOMOBILE INDUSTRY. R & D SEGMENT OF AKZO INDIA UNDERTAKES CONTRACT RESEARCH AND DEVELOPMENT FOR TH E AKZO GROUP. AKZO INDIA CARRIES OUT NOT IN RESEARCH AND DEVELOPMENT A CTIVITIES (COLOUR MIXING) ON THE BASIS OF THE SPECIFICATIONS RECEIVED FROM TH E AKZO GROUP. AKZO INDIA IS RESPONSIBLE FOR THE GLOBAL, REGIONAL REFINISHES MAR KET. R & D ACTIVITY IS TARGETED TOWARDS DEVELOPMENT OF UNFORTUNATELY FRIEN DLY AND TECHNOLOGY ADVANCES PRODUCTS AND DEVELOPMENT OF NEW COLOUR AKZ O INDIA DOES NOT OWN ANY SIGNIFICANT INTANGIBLE AND DOES NOT TAKE ANY SI GNIFICANT RESEARCH AND DEVELOPMENT ON ITS ACCOUNT THAT LEADS TO THE DEVELO PMENT AND NON WRITTEN INTANGIBLE. AKZO INDIA USES THE TRADE MARKS, PROCE SS AND KNOW-HOW TECHNOLOGICAL DATA SOFTWARE, OPERATING/QUALITY STAN DARD ETC DEVELOPED, OWNED BY AKZO GROUP. AKZO INDIA PROVIDES CONTRACT R & D SERVICES ONLY TO THE AKZO GROUP AND IS COMPENSATING ON THE COST PLUS PRE-DETERMINE BASIS AND THUS OPERATING IN AN OWNER RISK INSULATED ATMOSPHER E. AS A COST PLUS METHOD IS CONSIDERED AS COMPENSATION AS THE RISK INSULATED SERVICE PROVIDER, WHICH IS PAID IRRESPECTIVE OF THE SUCCESS OR FAILURE OF THE SERVICES RENDERED. THE LD. AR SUBMITTED THAT TCG LIFESCIENCES LTD, TRANSGENE B IOTEK LTD. ARE FUNCTIONALLY DIFFERENT FROM THE ASSESSEE COMPANY. AS TCG LIFESCIENCES LTD. IS ENGAGED IN CLINICAL RESEARCH PROJECT DEVELOPMENT AND IS IN PHARMACEUTICAL INDUSTRY. WHILE TRANSGENE BIOTECK LTD. IS ENGAGED AND MANUFACTURING DIAGNOSTIC PRODUCTS AND ALLIED SERVICES AND AGAIN I N PHARMACEUTICAL INDUSTRY. BOTH THESE COMPANIES OWN PATENT AND IPR WHICH ARE I NTANGIBLE ASSETS. THERE IS A HIGH RISK END FOR DEVELOPING PRODUCT FOR BOTH OF THIS COMPANIES. THEREFORE, 7 ITA NO. 6144 & 6007/DEL/2014 ITA THESE COMPANIES HAVE TO BE EXCLUDED. 14. THE LD. DR SUBMITTED THAT THE TPO HAS RIGHTLY I NCLUDED THESE COMPANIES AND THIS CONTENTION WAS NOT BEFORE THE CI T(A). THEREFORE, THE APPEAL OF THE ASSESSEE BE DISMISSED. 15. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON RECORD. TCG LIFESCIENCES LTD. AND TRANSGENE BIO TECK LTD. BOTH ARE FUNCTIONALLY DISSIMILAR. THEY ARE HAVING INTANGIBLE ASSETS WHICH ARE OWNED BY BOTH THE COMPANIES. THERE IS HIGH RISK INVOLVED BY BOTH THE COMPARABLES. THESE ARE FUNCTIONALLY DISSIMILAR BECAUSE THEY ARE INTO PHARMACEUTICAL INDUSTRY AND NOT IN AUTO MOBILE INDUSTRY. THUS, BO TH THESE COMPARABLES NEEDS TO BE EXCLUDED. THEREFORE, THE TPO/A.O IS DI RECTED TO EXCLUDE THESE TWO COMPARABLES. 10. AS REGARDS TO R & D COMPENSATION, THE SAID ISSU E IS ALSO CONSIDERED BY THE TRIBUNAL AND HELD AS UNDER: 16. AS RELATES TO R & D COMPENSATION, THE LD. AR S UBMITTED THAT THE TPO AS WELL AS CIT(A) HAS GROSSLY ERRED IN NOT APPR ECIATING THAT THE ASSESSEE AFTER DUE VERIFICATION AND APPLICATION SELECTED UNC ONTROLLED COMPARABLE COMPANIES BASED ON A DETAILED FUNCTIONAL ASSET AND RISK (FAR ANALYSIS). THE LD. AR FURTHER SUBMITTED THAT USING MULTIPLE YEAR/ AVERAGE DATA INSTEAD OF USING CURRENT YEAR DATA FOR COMPARABLE COMPANIES WH ICH WAS NOT AVAILABLE TO THE ASSESSEE,IS NOT PROPER ON PART OF TPO/A.O AS WE LL AS CIT(A). WORKING CAPITAL LEVELS WERE SIGNIFICANTLY DIFFERENT FROM TH E COMPARABLES WHICH WERE NOT TAKEN INTO ACCOUNT BY THE TPO AS WELL AS CIT(A) . THE LD. AR RELIED UPON THE ORDER OF THE ITAT IN THE ASSESSEES OWN CASE WH ERE IN PARA 29 DETAIL DISCUSSION WAS GIVEN. 17. THE LD. DR RELIED UPON THE ORDER OF THE TPO AN D THE CIT(A). 18. WE HAVE HEARD BOTH THE PARTIES AND PERUSED THE ORDER OF THE ITAT IN THE ASSESSEES OWN CASE FOR ASSESSMENT YEAR 2005-06 . IN THIS PARTICULAR YEAR ALSO, THE WORKING CAPITAL ADJUSTMENT WAS NOT C ONSIDERED BY TPO, THEREFORE, ITAT DIRECTED THE TPO TO DO THE NEEDFUL BY TAKING INTO ACCOUNT OF THE RELEVANT FACTORS WHICH WAS IGNORED ON THE EARLI ER OCCASIONS. HOWEVER, IT WOULD HAVE TO BE DECIDED FRESH ONLY AFTER THE FRESH COMPARABLES ARE CHOSEN BY THE TPO WHICH ARE SIMILAR TO THE FUNCTION SEGMEN T AND OWNERSHIP OF THE ASSETS. 8 ITA NO. 6144 & 6007/DEL/2014 ITA 19. IN RESULT, THE ASSESSEES APPEAL BEING ITA NO. 3005/DEL/2014 IS PARTLY ALLOWED FOR STATISTICAL PURPOSE. IN THIS PARTICULAR YEAR ALSO, THE WORKING CAPITAL ADJUSTMENT WAS NOT CONSIDERED BY TPO, THEREFORE, WE DIRECT THE TPO TO DO THE NEEDFUL BY TAKING INTO ACCOUNT THE RELEVANT FACTORS WHICH WAS IGNORED ON THE EARLIER OCCASIONS. HOWEVER, IT WOULD HAVE TO BE DECIDED AFRESH ONLY AF TER THE FRESH COMPARABLES ARE CHOSEN BY THE TPO WHICH ARE SIMILAR TO THE FUNC TIONAL SEGMENT AND OWNERSHIP OF THE ASSETS OF THE ASSESSEE COMPANY. 11. THUS, BOTH THE ISSUES ARE DECIDED BY THE TRIBUN AL BY DIRECTING THE TPO/AO TO DECIDE AS PER THE DIRECTIONS OF THE TRIBU NAL. SIMILAR DIRECTIONS ARE ISSUED IN THE PRESENT APPEAL AS WELL. 12. IN RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALL OWED. ORDER PRONOUNCED IN THE OPEN COURT ON 24TH JULY, 2018 . SD/- SD/- (N. K. SAINI) (SUCHITRA KAMBLE) ACCOUNTANT MEMBER JUDICIAL MEM BER DATED: 24/07/2018 R. NAHEED COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI 9 ITA NO. 6144 & 6007/DEL/2014 ITA DATE OF DICTATION 23.07.2018 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 23.07.2018 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 24.07.2018 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT 24.07.2018 DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 24.07.2018 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 10 ITA NO. 6144 & 6007/DEL/2014 ITA