ACIT, Haridwar V. M/s. Dev Bhoomi Steels Pvt. Ltd., Haridwar

ITA 6332/DEL/2013

• Counselvise Citation: [2015] 121 COUNSELVISE.COM (IT) 1709 (ITAT-DELHI)
• Duration Of Justice: 1 year(s) 10 month(s) 10 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-10-2015
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: B
• Next Hearing Date: 05-10-2015
• Assessment Year: 2008-2009
• Appeal Filed On: 29-11-2013
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Section: 143(3); 133(6); 131; 68; 148

Judgement Text

ACIT V DEV BHOOMI STEELS PRIVATE LIMITED ITA NO 6332 & 6333 /DEL/2013 A Y 2008-09 AND 2009-10 PAGE 1 OF 7 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH B, NEW DELHI BEFORE SH. I.C.SUDHI R, J.M AND SH. PRASHANT MAHARISHI, AM ITA NO. 6332 & 6333/DEL/2013 A. Y. : 2008-09, 2009-10 ACIT, CIRCLE, HARIDWAR HARIDWAR VS DEV BHOOMI STEELS PVT. LTD. D-10/11, BAHADRABAD INDL. AREA HARIDWAR (APPELLANT) (RESPONDENT) PAN AABCD9137D ASSESSEE BY SHRI SUJIT KUMAR, SR. DR REVENUE BY SHRI GAUTAM JAIN, ADV. DATE OF HEARING : 5. 10.2015 DATE OF PRONOUNCEMENT : 09 .10.2015 ORDER PER PRASHANT MAHARISHI, AM: 01. THESE TWO APPEALS FOR AY 2008-09 AND 2009-10 ARE D IRECTED BY REVENUE AGAINST THE ORDERS OF CIT (A) DATED 23/9/2013 AND 24/09/2013 DELETING THE ADDITION OF RS 17,00,296/- AND RS. 12,00,652/- RESPECTIVELY BEING NET PROFIT ON ACCOUNT OF ALLEGED FAKE CASH SALES. BOTH THESE APPEALS ARE BEING DECID ED BY A COMMON ORDER, AS IT WAS THE COMMON STAND OF THE PARTIES BEFORE THE BENCH TH AT THE ARGUMENTS ADVANCED ARE SAME DUE TO SIMILARITY IN FACTS AND LAW WOULD APPLY MUTATIS MUTANDIS TO BOTH THE APPEALS. 02. BRIEF FACTS OF THE CASE IS THAT ASSESSEE IS A PRIV ATE LIMITED COMPANY ENGAGED IN MANUFACTURING OF M S INGOTS AT HARDIWAR AND INCOME DERIVED BY THE COMPANY FORM ITS ELIGIBLE UNIT IS SUBJECT TO DEDUCTION U/S 80 IC OF THE INCOME TAX ACT. A. FOR A Y 2008-09 IT FILED ITS RETURN OF INCOME ON 2 9.09.2008. IN ASSESSMENT PROCEEDINGS, U/S 143(3) OFTHE ACT AOISSUED INQUIRYL ETTERS U/S 133(6) OF THE ACT TO SOME OF THE PARTIES TO WHOM SALES WERE MADE IN CASH. OUT OF WHICH ONE INQUIRY LETTER ADDRESSED TO SHRI NAVINJAIN AT MANDI GOBINDGARH PUNJAB CAMEBACK WITH POSTAL REMARKS REFUSED TO ACCEPT. T HEREFORE,AO REQUESTEDJURISDICTIONAL ADDL. COMMISSIONER OF INCOM E TAX AT MANDI ACIT V DEV BHOOMI STEELS PRIVATE LIMITED ITA NO 6332 & 6333 /DEL/2013 A Y 2008-09 AND 2009-10 PAGE 2 OF 7 GOBINDGARH FOR APPROPRIATE ACTION. AFTER GIVING THE OPPORTUNITY OF HEARING TO THE ASSESSEE, ASSESSMENT WAS MADE TREATING THAT SAL ES MADE TO MR NAVIN JAIN AS INGENUINE. SUBSEQUENTLY A LETTER WAS RECEIVED FROM ADDL COMMISSIONER OF INCOME TAX, MANDI GOBINDGARH STATING THAT SHRI NAVI N JAIN IS NOT HAVING ANY TRANSACTIONS WITH THE ASSESSEE COMPANY AND HIS SOUR CES OF INCOME IS BROKERAGE AND SALARY. THEREFORE AO RECORDED THE REASONS AND ISSUE NOTICE U/S 148 OF THE ACT ON 28/06/2010 HOLDING THAT INCOME OF RS 1,60,56 ,844/- HAS ESCAPED THE ASSESSMENT. IN RESPONSE TO THIS ASSESSE, REQUESTED AO TO TREAT THE ORIGINAL RETURN FIELD AS RETURNED FILED IN RESPONSE TO THE NOTICE U/S 148 AND PRODUCED BOOKS OF ACCOUNTS, BILLS, AND VOUCHERS, WHICH WERE TEST CHECKED BY AO. FURTHER AO CONDUCTED INQUIRIES IN CASE OF ANOTHER P ARTY AND FOUND THAT ITDID NOT EXIST AT THE GIVEN ADDRESS. FURTHER AO CHECKED THE INFORMATION AVAILABLE ONLINE ON SALES TAX WEBSITE SHOWING THAT REGISTRATI ON NUMBER OF THAT PARTY WAS CANCELLED ON 4-1-2006 I.E. BEFORE COMMENCEMENT OF A CCOUNTING YEAR RELEVANT TO THIS AY. THEREFORE AO ASKED ASSESSEE TO FILE DET AILS WITH RESPECT TO OTHER PARTIES ALSO FOR WHICH ASSESSEE SUBMITTED THAT IT I S NOT POSSIBLE TO SUBMIT THEIR DETAILS BUT EXPLAINED THAT IT HAS RELIED ON INFORMA TION GIVEN BY THE PURCHASERS AND ALSO STATED THAT SINCE THE PURCHASES OF GOODS H AVEBEENACCEPTED MERELY BECAUSE SALES IS MADE IN CASH, NO ADDITIONS CAN BE MADE. THEREFORE AO WAS OF THE VIEW THAT CASH SALES MADE BY THE ASSESSEE OF RS . 6,25,10,89/- IS BOGUS AND HENCE AFTER COMPARING STOCK TURNOVER AND G P RAT IO WITH OTHER COMPANY HAS ESTIMATED NET PROFIT @ 2.72% AT RS 17,00,296/- AND ADDED THE SAME AS UNDISCLOSED INCOME U/S 68 AND DENIED THE BENEFIT O F SECTION 80 IC ON THAT. AGAINST THIS ASSESSEE PREFERRED APPEAL BEFORE CIT ( A) WHO ALLOWED THE APPEAL OF THE ASSESSEE AND THEREFORE REVENUE IS NOW AGGRIE VED AND IS IN APPEAL BEFORE US RAISING SEVERAL GROUNDS OF APPEAL BUT EFFECTIVE LY CONTESTING THE DELETION OF ADDITION OF RS 17,00,296/- ON ACCOUNT OF FAKE CASH SALES. B. FOR AY 2009-10 ASSESSEE FIELD RETURN OF INCOME ON 30.9.2009 FOR RS 10260/- AFTER CLAIMING DEDUCTION U/S 80 IC OF RS 7170850/- . DURING THAT YEAR ASSESSEE HAS CLOCKED SALES OF RS. 32,22,43,737/- OUT OF W HICH CASH SALES IS RS. 4,69,00,467/-. DURING THE COURSE OF ASSESSMENT, AO ASKED FOR THE DETAILS OF CASH SALES MADE BY THE ASSESSEE SUCH AS NAMES AND A DDRESS OF THE PARTIES. HOWEVER, ASSESSEE SUBMITTED ONLY THE FIGURE OF CASH SALES BUT DID NOT FURNISH ACIT V DEV BHOOMI STEELS PRIVATE LIMITED ITA NO 6332 & 6333 /DEL/2013 A Y 2008-09 AND 2009-10 PAGE 3 OF 7 THE NAMES AND ADDRESS OF THE PARTIES. IN ABSENCE OF THESE DETAILS, AO MADE ADDITION OF RS 12,00,652/- BEING 2.56 % OF THE CASH SALES AS NET PROFIT OF THE ASSESSEE BASED ON COMPARISON WITH OTHER PARTIES. AS SESSEE AGGRIEVED WITH THE ORDER OF AO PREFERRED APPEAL BEFORE CIT (A) WHO DEL ETED THE ADDITION RELYING ON THE ORDER IN CASE OF ASSESSEE FOR AY 2008-09. AG AINST THIS REVENUE IS IN APPEAL BEFORE US. 03. BEFORE US, THE LD. DR SUBMITTED THAT AO HAS CONCLUS IVELY FOUND THAT FOR AY 2008-09 SOME OF THE PARTIES TO WHOM CASH SALES HAVE BEEN MA DE ARE NOT IN EXISTENCE OR ARE OF SMALL MEANS AND NOT HAVING ANY BUSINESS DEALING WIT H THE ASSESSEE. THEREFORE AO HAS WORKED OUT A COMPARABLE NET PROFIT EARNED BY THE AS SESSEE OF RS 17,00,296/- AND DENIED THE BENEFIT OF DEDUCTION U/S 80 IC ON THAT A MOUNT. HE FURTHER JUSTIFIED THAT ADDITION U/S 68 OF THAT AMOUNT IS RIGHTLY MADE BY A O. HE ALSO SUBMITTED THAT CIT (A) HAS ERRED IN DELETING THE ADDITION WITHOUT APPREC IATING THE FACTS OF THE CASH SUCH AS NON-EXISTENCE OF SOME OF THE PARTIES AND DENIAL BY THEM OF HAVING ANY BUSINESS CONNECTION WITH THE ASSESSEE. HE FURTHER SUBMITTED THAT EXCISE AND SALES TAX DEPARTMENTS ARE NOT CONCERNED WITH THE BOOKING OF S ALES IN CASH AND THEREFORE THERE VERIFICATION DOES NOT JUSTIFY THE DELETION OF THE A DDITION. THEREFORE, HE SUBMITTED THAT ORDER OF AO BE RESTORED. 04. IN RESPONSE TO THIS LD AR SUBMITTED THAT FOR AY 200 8-09 BOOKS OF ACCOUNTS WERE PRODUCED BEFORE AO ALONG WITH THE VOUCHER AND BILLS AND THOSE WERE EXAMINED. THOSE BOOKS WERE ALSO PRODUCED BEFORE CIT (A) AT HI S DIRECTION FOR VERIFICATION. FURTHER ORIGINAL ASSESSMENT FOR THAT YEAR WAS ALSO COMPLETED U/S 143(3) OF THE ACT WHERE IN 133 (6) INQUIRY LETTERS WERE SENT TO OTHER PARTIES ALSO AND IN THAT PROCEEDINGS THE BOOKS OF ACCOUNTS WERE PRODUCED. NO NE OF THE AUTHORITIES COULD FIND ANY DEFECT IN THE BOOKS OF ACCOUNTS. FURTHER, HE SU BMITTED THAT WHEN THE PURCHASES QUANTITY IS ACCEPTED BY AO THEN SALES OF THAT QUA NTITY COULD NOT BE DISPUTED MERELY BECAUSE THE SALES HAVE TAKEN PLACE IN CASH. FURTHER AO HIMSELFHAS ACCEPTED THE OVERALL BOOK RESULTS BUT ESTIMATED PROFIT ON CASH S ALE ONLY, WHICH IS INCORRECT WHEN OVERALL BOOKS OF ACCOUNTS ARE ACCEPTED. HE ALSO SUB MITTED THAT AT PARA NO 5 OF THE ASSESSMENT ORDER AO HAS ACCEPTED THE INCOME DECLARE D BY THE ASSESSEE OF RS. 82,73,371/- AND ALSO GRANTED DEDUCTION U/S 80 IC OF THE SAME AMOUNT AND THEN MAKING AN ADDITION OF RS 17,00,296/- BEING N P ON CASH SAL ES WHEN CASH SALES IS ALREADY PART OF THE PROFIT SHOWN BY THE ASSESSEE. HE FURTHER SUB MITTED THAT AO HAS ESTIMATED THE ACIT V DEV BHOOMI STEELS PRIVATE LIMITED ITA NO 6332 & 6333 /DEL/2013 A Y 2008-09 AND 2009-10 PAGE 4 OF 7 NET PROFIT ON CASH SALES AND MADE ADDITION U/S 68 O F THE ACT WHERE THE SALESIS ALREADY CREDITED TO THE PROFIT AND LOSS ACCOUNT. HE ALSO SU BMITTED THAT CIT (A) HASSEEN THE DAILY SALES AND POSITION OF STOCK AND HELD THAT THE RE IS NO DISCREPANCY IN THE DETAILS AND THEREFORE ADDITION HAS BEEN RIGHTLY DELETED. HE FURTHER SUBMITTED THAT FACTS OF THE CASE FOR AY 2009-10 ARE ALSO ON SIMILAR LINES. 05. LD. DR IN REJOINDER SUBMITTED THAT IT IS A COMMON PRACTICE TO IDENTIFY THE COMPARABLE FOR THE COMPARISON OF NET PROFIT AND REGARDING ADDI TION OF GROSS PROFIT HE SUBMITTED THAT IF THERE IS AN ERROR MADE BY AO, IT MAY BE COR RECTED BY THE TRIBUNAL. 06. WE HAVE CAREFULLY CONSIDERED THE RIVAL SUBMISSION A ND ORDERS OF LOWER AUTHORITIES. ASSESSEE IS A COMPANY ENGAGED IN MANUFACTURING OF M S INGOTS AT HARIDWAR AND UNDISPUTEDLY ELIGIBLE FOR DEDUCTION U/S 80 IC OF TH E ACT. WHILE GOING THROUGH ORDERS OF LOWER AUTHORITIES WE HAVE COME TO AN UNDERSTANDING THAT THE FACTS OF THE CASE FOR BOTH THE YEARS ARE NOT SIMILAR HOWEVER, THE MANNER OF MA KING ADDITIONS IS SIMILAR. IN THIS BACKGROUND WE ARE DECIDING THE ISSUE FOR BOTH THE Y EARS SEPARATELY AS UNDER. 07. FOR AY 2008-09, COMPANY RECORDED SALES OF RS. 31,03 ,42,972/- OUT OF WHICH RS 6,25,10,899/- IS RECORDED AS CASH SALES. ON INQUIRY IN ORIGINAL ASSESSMENT, ONE SHRI NAVIN JAIN BUYER OF THE GOODS IN CASH REFUSED TO ACCEPT THE INQUIRY LETTER AND THEREFORESUBSEQUENTLY FURTHER INQUIRIES WERE MADE AND BASED ON THAT IT IS ALLEGED THAT SHRI NAVIN JAIN HAS DENIED THE TRANSACTIONS WITH TH E ASSESSEE.FURTHER, IN CASE OF SECOND PARTY M/S MALHOTRA STAMPINGS SUCH PARTY WAS NOT AVAILABLE AT THE GIVEN ADDRESS. IN CASE OF OTHER PARTIES, SHREEGANAPATI ST EELS INDUSTRIES AND GANAPATI STEEL MILLS ASSESSEE EXPRESSED ITS INABILITY TO PRODUCE D ETAILS CALLED FOR. HOWEVER, ASSESSEE PRODUCED BEFORE AO CST REGISTRATION FORMS AS WELL A S C FORMS MADE AVAILABLE BY THE PURCHASERS. THEREFORE IT IS NOT IN DISPUTE THAT FOR AY 2008-09 , ASSESSEE HAS SUBMITTED THE COMPLETE DETAILS AVAILABLE WITH IT SU CH AS NAMES, ADDRESS, DETAILS OF SALES TAX REGISTRATION, COPIES OF C FORMS SUBMITTED BY THE PURCHASERS, SALES BILLS SHOWING THE QUANTITY SOLD, RATES AND AMOUNT RECEIV ED ETC. ASSESSEE IS MANUFACTURER OF THE GOODS AND AFTER MANUFACTURING;THESE GOODS HA VE BEEN SOLD EITHER IN CASH OR CHEQUE OR ON CREDIT. THE MANUFACTURING DETAILS IN Q UANTITY AND IN VALUE HAVE BEEN FURNISHED TO EXCISE AUTHORITIES, AMOUNT OF SALES AL ONG WITH THE C FORMS ETC. IS SUBMITTED TO SALES TAX AUTHORITIES BY ASSESSEE, AND IT WAS NOT DISPUTED. FURTHER CIT (A) HAS ALSO HELD THAT ASSESSEE HAS MAINTAINED DAILY SALES AND POSITION OF STOCK IN THE STOCK REGISTER AND THE CASH RECEIVED RECORDED IN TH E CASHBOOK. FURTHER, HE HELD THAT ACIT V DEV BHOOMI STEELS PRIVATE LIMITED ITA NO 6332 & 6333 /DEL/2013 A Y 2008-09 AND 2009-10 PAGE 5 OF 7 ASSESSEES OWN EVIDENCE SUCH AS SALES VOUCHER MENTI ONING TRUCK NUMBERS, WEIGHT, RATES ETC. IS ALSO PRODUCED BEFORE AO AS WELL AS BE FORE CIT (A). IT IS ALSO NOT ALLEGED BY THE REVENUE THAT RATES MENTIONED IN THOSE SALES ARE NOT COMPARABLE OR THE GOODS HAVE NOT MOVED OUT OF THE FACTORY OF ASSESSEE. MERE LY BECAUSE SOME OF THE PERSONS WHO HAVE PURCHASED GOODS FROM THE ASSESEEE IN CASH AND ISSUED SALES TAX FORMS TO THE ASSESSEE, HAVE NOT RESPONDED TO THE QUERIES OR REFU SES THE TRANSACTIONS CANNOTBE THE SOLE BASIS FOR THE MAKING OF THIS KIND OF ADDITION PARTICULARLY WHEN THE SALES ON CREDIT OR THROUGH CHEQUES AND PURCHASES AND PRODUCTION OF THE GOODS IS ACCEPTED. FURTHER AO HAS ALSO NOT EXAMINED THESE PARTIES BY ISSUING S UMMONS U/S 131 OF THE ACT AND THEN CONFRONTING THE ASSESSEE BY GIVING AN OPPORT UNITY OF CROSS-EXAMINATION.IT MAY BE POSSIBLE THAT THOSE PARTIES WILL NOT HAVE RECORD ED THESE TRANSACTIONS.UNLESS IT IS PROVED THAT GOODS HAVE NOT MOVED OUT OF THE FACTORY , SALE PRICES MENTIONED IN THE SALES INVOICES ARE NOT CONTEMPORARY AND QUANTIT Y IS NOT BORNE OUT FROM RECORDS OF THE MANUFACTURING ACTIVITIES OF THE ASSESSEE, MEREL Y BECAUSE THE PARTIES WHO HAVE PURCHASED FROM ASSESSEE IN CASH BY GIVING PROPER SA LES TAX C FORMS ARE NOT TRACEABLE, NO ADVERSE INFERENCE CAN BE DRAWN AGAINST THE ASSES SEE. IT IS ALSOINTERESTING THAT THOUGH ASSESSEE HAS CREDITED THE FULL SALES REALISE D IN CASH IN THE PROFIT AND LOSS ACCOUNT AS CASH SALES STILL AO HAS MADE AN ADDITION U/S 68 OF THE ACT OF ONLY NET PROFIT EARNED BY THE ASSESSEE. IN FACT, NET PROFIT IS NOT SUM CREDITED IN THE BOOKS OF THE ASSESSEE BUT IT IS A RESULT OF TRADING TRANSACTIONS OF SALES, PURCHASES, AND EXPENSES AND TO OURMIND, PROVISIONS OF SECTION 68 DOES NOT ALLY TO NET PROFIT BUT TO SUM CREDITED IN THE BOOKS OF ACCOUNTS.THEREFORE, FOR AY 2008-09, WE CONFIRM THE ORDER OF CIT (A) IN DELETING THE ADDITION OF RS.17,00,296/- BEING N P O N CASH SALES. WE DISMISS THE APPEAL OF THE REVENUE FOR AY 2008-09. 08. FOR AY 2009-10, ASSESSEE COMPANY HAS RECORDED GROSS SALES OF RS 32,22,43,737/- OUT OF WHICH CASH SALES IS RS. 4,69,00,467/-. AO HAS MA DE ADDITION OF RS 12,00,562/- BEING NET PROFIT ON CASH SALES ADOPTING THE COMPARA BLE CASES. IN ASSESSMENT, ASSESSEE HAS NOT PRODUCED ANY DETAILS OF CASH SALES EXCEPT T HE AMOUNT OF CASH SALES DESPITE RELEVANT DETAILS REPEATEDLY ASKED BY AO. THEREFORE, IN AY 2009-10 ASSESSEE HAS NOT PROVIDED ANY RELEVANT DETAILS ON WHICH AO COULD HAV E MADE ANY INQUIRY OF CASH SALES IN CONTRADISTINCTION TO FACTS OF AY 2008-09 WHERE A SSESSEE HAS PROVIDED THE RELEVANT DETAILS AVAILABLE WITH IT INCLUDING C FORMS ISSUED BY THE PARTIES. THEREFORE, FOR THIS YEAR AO WAS HANDICAPPED IN ABSENCE OF ANY DETAILS A ND MADE ADDITION OF NET PROFIT OF ACIT V DEV BHOOMI STEELS PRIVATE LIMITED ITA NO 6332 & 6333 /DEL/2013 A Y 2008-09 AND 2009-10 PAGE 6 OF 7 RS 12,00,652/- U/S 68. LD CIT (A) HAS DELETED THE A DDITION BASED ON HIS ORDER FOR AY 2008-09 WITHOUT APPRECIATING THAT AS COMPARED TO AY 2008-09 WHERE ASSESSEE HAS FURNISHED RELEVANT DETAILS IN AY 2009-10 ASSESSEE H AS NOT FURNISHED ANY DETAILS EXCEPT THE AMOUNT OF CASH SALES. FURTHER, IN THIS Y EAR THERE IS NO FINDING WHETHER EVEN CIT (A) HAS EXAMINED THE SALES AND VERIFIED THE BOO KS AS HE HAS DONE IN AY 2008- 09.THEREFORE, IN OUR OPINION, CIT (A) HAS COMMITT ED AN ERROR IN DELETING THE ADDITION FOR AY 2009-10 FOLLOWING HIS ORDER IN CASE OF ASSES SEE FOR AY 2008-09 IN ABSENCE OF ANY DETAILS OF CASH SALES AND IN ABSENCE OF ANY INQ UIRY MADE BY CIT (A).THEREFORE, IN THE INTEREST OF JUSTICE, WE SET ASIDE THE APPEAL OF AY 2009-10 BACK TO THE FILE OFAO WITH A DIRECTION TO INQUIRE, VERIFY, AND DEAL WITH CASH SALES RECORDED BY THE ASSESSEE IN ACCORDANCE WITH LAW AFTER AFFORDING SUFFICIENT A ND NECESSARY OPPORTUNITY OF HEARING TO THE ASSESSEE.THUS, APPEAL OF THE REVENUE IS ALLO WED FOR STATISTICAL PURPOSES. 09. IN THE RESULT APPEAL OF THE REVENUE FOR AY 2008-09 IN ITA NO 6332/DEL/2013 IS DISMISSED AND FOR AY 2009-10 IN ITA NO 6333/DEL/201 3 IS ALLOWED FOR STATISTICAL PURPOSES. 10. (ORDER PRONOUNCED IN THE COURT ON 09/10/2015) SD/- SD/- (I.C.SUDHIR) (PRASHANT MAHARISHI) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED:09 /10/2015 *B. RUKHAIYAR* COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR ACIT V DEV BHOOMI STEELS PRIVATE LIMITED ITA NO 6332 & 6333 /DEL/2013 A Y 2008-09 AND 2009-10 PAGE 7 OF 7 DATE INITIAL 1. DRAFT DICTATED ON 08/10/2015 2. DRAFT PLACED BEFORE AUTHOR 08/10/2015 3. DRAFT PROPOSED & PLACED BEFORE THE SECOND MEMBER 08/10/2015 4. DRAFT DISCUSSED/APPROVED BY SECOND MEMBER. 08/10/2015 5. APPROVED DRAFT COMES TO THE SR.PS/PS 6. KEPT FOR PRONOUNCEMENT ON 7. FILE SENT TO THE BENCH CLERK 09/10/2015 8. DATE ON WHICH FILE GOES TO THE AR 9. DATE ON WHICH FILE GOES TO THE HEAD CLERK. 10. DATE OF DISPATCH OF ORDER.