Appeal details
Counselvise Citation
[2019] 117 COUNSELVISE.COM (IT) 2562 (ITAT-DELHI)
Assessee PAN
Bench
Appeal Number
Duration Of Justice
3 year(s) 4 month(s) 8 day(s)
Appellant
Respondent
Appeal Type
Income Tax Appeal
Pronouncement Date
19-06-2019
Appeal Filed By
Assessee
Order Result
Allowed
Bench Allotted
F
Assessment Year
2012-2013
Appeal Filed On
10-02-2016
Judgement Text
1 ITA NO. 715/DEL/2016 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: F NEW DELHI BEFORE SHRI R. K. PANDA, ACCOUNTANT MEMBE R AND MS SUCHITRA KAMBLE, JUDIC IAL MEMBER ITA NO. 715/DEL/2016 ( A. Y 2012-13) PURE SOFTWARE PVT. LTD. C/O. M/S RRA TAX INDIA, D-28, SOUTH EXTENSION, PART-1 NEW DELHI AADCP5432B (APPELLANT) VS ITO WARD-20(2) C. R. BUILDING NEW DELHI (RESPONDENT) APPELLANT BY DR. RAKESH GUPTA, SH. SOMIL AGGARWAL, SH. DEEPESH GARG, & SH. SHUBHAM SOBTI, ADVS RESPONDENT BY SH. SURENDER PAL, SR. DR ORDER PER SUCHITRA KAMBLE, JM THIS APPEAL IS FILED BY THE ASSESSEE AGAINST THE OR DER DATED 23/12/2015 PASSED BY CIT(A)-7 FOR ASSESSMENT YEAR 2012-13. 2. THE GROUNDS OF APPEAL ARE AS UNDER:- 1. THAT HAVING REGARD TO THE FACTS AND CIRCUMSTANCES OF THE CASE, LD. CIT(A) HAS ERRED IN LAW AND ON FACTS IN CONFIRMING THE ACT ION OF LD. AO IN MAKING DISALLOWANCE OF RS.20,02,770/- U/S 40(A)(I) OF THE ACT ON ACCOUNT OF NON DEDUCTION OF TDS ON PAYMENT MADE TO TWO NON-RESIDEN TS I.E. J2S INC, USA AND NAVOS B.V.B.A., BELGIUM AND IN INVOKING THE PRO VISIONS OF SECTION 195 OF THE ACT. 2. THAT IN ANY CASE AND IN ANY VIEW OF THE MATTER, AC TION OF LD. CIT(A) IN CONFIRMING THE ACTION OF LD. AO IN MAKING DISALLOWA NCE OF RS.20,02,770/- U/S 40(A)(I) FOR NON DEDUCTION OF TAX ON PAYMENT MADE T O TWO NON-RESIDENTS I.E. DATE OF HEARING 06.06.2019 DATE OF PRONOUNCEMENT 19.06.2019 2 ITA NO. 715/DEL/2016 J2S INC, USA AND NAVOS B.V.B.A., BELGIUM, IS BAD IN LAW AND AGAINST THE FACTS AND CIRCUMSTANCES OF THE CASE. 3. THAT HAVING REGARD TO THE FACTS AND CIRCUMSTANCES OF THE CASE, LD. CIT(A) HAS ERRED IN LAW AND ON FACTS IN CONFIRMING THE ACT ION OF LD. AO IN TREATING THE ORDER PROCUREMENT SERVICES RENDERED BY THE NON RE SIDENTS AND COMMISSION /RETAINER FEE AS ROYALTY AND FEES FOR TECHNICAL SER VICES AND IGNORING THE FACT THAT THE ORDER PROCUREMENT SERVICES RENDERED OUTSID E INDIA ARE NOT TAXABLE IN INDIA. 3. THE ASSESSEE COMPANY IS ENGAGED IN THE BUSINESS OF SOFTWARE DEVELOPMENT, TESTING AND TRAININGS. THE ASSESSEE FI LED ITS RETURN OF INCOME ON 22.09.2012 FOR A.Y. 2012-13 DECLARING INCOME OF RS. 14,63,886/- AS DEEMED INCOME U/S 115JB. THE CASE WAS TAKEN UP BY THE ASSE SSING OFFICER FOR SCRUTINY. DURING THE COURSE OF SCRUTINY, THE ASSESS ING OFFICER ASKED FOR THE DETAILS OF PROFESSIONAL EXPENSES AMOUNTING TO RS. 7 3,99,546/-. THIS SUM INCLUDED TWO PAYMENTS AS FOLLOWS:- J2S INC, USA RS. 13,44,524/ - NAVOS B.V.B.A, BELGIUM RS.6,58,242/ - THE ASSESSING OFFICER OBSERVED THAT NO TAX WAS DED UCTED AT SOURCE ON THESE PAYMENTS UNDER SECTION 195 OF THE INCOME TAX ACT. BOTH THESE PARTIES ARE NON-RESIDENTS. THEY HAVE RENDERED THE ORDER PROCURE MENT SERVICES ABROAD AND HAVE NO BUSINESS CONNECTION OR PERMANENT ESTABLISHM ENT IN INDIA. SINCE THEIR INCOME WAS NOT CHARGEABLE UNDER THE PROVISIONS OF I .T. ACT READ WITH SECTION 5 AND 9, NO TAX WAS DEDUCTIBLE UNDER SECTION 195 OF T HE I.T. ACT. WITHOUT PREJUDICE TO THE ABOVE, THE SERVICES RENDERED BY BO TH THE ABOVE PARTIES ARE NEITHER ROYALTY NOR FEES FOR TECHNICAL SERVICES. IN THE PREVIOUS YEAR RELEVANT TO A.Y. 2012- 13, ONLY THE RETAINER FEE WAS PAID AND N O SERVICES INFACT WERE RENDERED BY THE ABOVE PARTIES AND HENCE PROVISIONS OF SECTION 9(L)(VII) WILL NOT BE ATTRACTED. EVEN OTHERWISE, SUCH SERVICES WHEN RE NDERED WILL FALL UNDER THE EXCEPTION CLAUSE OF SUB-CLAUSE (B) OF CLAUSE (VII) OF SUB-SECTION (1) OF SECTION 9 AS SUCH SERVICE ARE FOR THE PURPOSE OF MAKING OR EA RNING ANY INCOME FROM THE 3 ITA NO. 715/DEL/2016 CUSTOMERS OUTSIDE INDIA. EVEN THEN, THE ASSESSING O FFICER HAS CONSIDERED THESE PAYMENTS IN THE NATURE OF ROYALTIES AND FEES FOR TE CHNICAL SERVICES WITHIN THE MEANING OF SECTION 9(1 )(VII) OF THE I.T. ACT AND H AS MADE DISALLOWANCE OF RS.20,02,767/- U/S 40(A)(I) OF THE I.T. ACT AND ASS ESSED THE INCOME AT RS. 20,02,767/- AS AGAINST THE RETURNED INCOME OF RS. 1 4,63,886/-. WHILE ARRIVING AT THE ASSESSED INCOME OF RS.20,02,770/-. THE ASSES SING OFFICER ALSO ADJUSTED THE BROUGHT FORWARD LOSS OF RS.30,27,046/- AS AGAIN ST THE ASSESSED BROUGHT FORWARD LOSS OF RS.42,88,991/- OF THE A.Y. 2009-10. 4. BEING AGGRIEVED BY THE ASSESSMENT ORDER, THE ASS ESSEE FIELD APPEAL BEFORE THE CIT(A). 5. THE LD. AR SUBMITTED THAT DISALLOWANCE U/S 40(A) (IA) WILL BE APPLICABLE WHEN TAX DEDUCTABLE AT SOURCE UNDER CHAPTER XVII B HAS NOT BEEN DEDUCTED UNDER CHAPTER XVII B. THE RELEVANT SECTION IS SECT ION 195 WHICH REQUIRES ANY PERSON TO DEDUCT INCOME TAX FROM ANY PAYMENT MADE T O A NON-RESIDENT WHEN SUCH PAYMENT IS CHARGEABLE UNDER THE PROVISIONS OF THE INCOME TAX ACT. THUS, NO DEDUCTION OF TAX AT SOURCE WILL BE APPLICABLE WH EN THE PAYMENT OF THE NON- RESIDENT IS NOT TAXABLE IN INDIA. THE CHARGING SEC TION IS SECTION 5(2) WHICH STATES THAT IF ANY INCOME IS RECEIVED OR DEEM TO BE RECEIVED IN INDIA IN THE HANDS OF A NON-RESIDENT OR ACCRUES OR ARISES OR IS DEEM TO ACCRUE OR ARISE IN INDIA TO THE NON-RESIDENT, SAME SHALL BE TAXABLE IN INDIA. EXPLANATION 1 TO SECTION 5 STATES THAT INCOME ACCRUING OR ARISING OU TSIDE INDIA SHALL NOT BE DEEM TO BE RECEIVED IN INDIA BY REASON ONLY OF THE FACT THAT IT IS TAKEN INTO ACCOUNT IN A BALANCE-SHEET PREPARED IN INDIA. IN C ASE OF THE ASSESSEE COMPANY, TWO NON-RESIDENT FOREIGN COMPANIES, ONE BY THE NAME OF J2S INC, USA AND ANOTHER BY THE NAME OF NAVOS, BELGIUM WERE APPOINTED TO LOCATE FOREIGN BUYERS TO WHOM THE ASSESSEE COMPANY COULD S ALE ITS SERVICES. THUS, BOTH THE FOREIGN COMPANIES RENDERED ORDER PROCUREME NT SERVICES OUTSIDE INDIA WHICH IS THEIR BUSINESS ACTIVITY. INVOICES RECEIVE D FROM THE PARTIES ALSO SHOW THAT SERVICES RENDERED BY THEM WERE SALES PROCUREME NT SERVICES AND NOT FEES 4 ITA NO. 715/DEL/2016 FOR TECHNICAL SERVICES OR ROYALTIES. THE LD. AR SU BMITTED THAT THE ASSESSING OFFICER WRONGLY ALLEGED IN PARA 2.3 OF HIS ORDER TH AT SERVICES RENDERED BY THE ABOVE PARTIES WHERE FROM ROYALTIES OR FEE FOR TECHN ICAL SERVICES. IT SHOWS THAT THE ASSESSING OFFICER HIMSELF WAS NOT SHOW AS TO WH ETHER THE INCOME RECEIVED BY NON RESIDENCE WAS ROYALTY OR FEE FOR TECHNICAL S ERVICES. IN PARA 2.4 OF HIS ORDER, THE ASSESSING OFFICER QUOTED ARTICLE 12 OF THE DTAA BETWEEN INDIA AND BELGIUM WHICH HAS GIVEN THE DEFINITION OF BOTH ROY ALTY AND FEES FOR TECHNICAL SERVICES. THE LD. AR SUBMITTED THAT IN A CASE OF A SSESSEE COMPANY BOTH THE FOREIGN PARTIES FOR RENDERED OR PROCUREMENT SERVICE S AS THEIR BUSINESS ACTIVITY AND FOR WHICH THEY WERE PAID COMMISSION/RETAINER SH IP FEE. THESE SERVICES CAN NEITHER BE CALLED AS TECHNICAL OR CONSULTANCY SERVI CES NOR AS A ROYALTY AS PER DEFINITION GIVEN IN THE RELEVANT ARTICLE TO DTAA. NONE OF THESE TWO COMPANIES WERE HAVING ANY OFFICE OR PERMANENT ESTABLISHMENT I N INDIA. NO PAYMENT WAS RECEIVED BY THESE NON-RESIDENT PARTIES IN INDIA AND THUS THEIR INCOME WAS NOT TAXABLE IN INDIA AND ACCORDINGLY SUB-SECTION 2 OF S ECTION 5 WAS NOT ATTRACTED AND CONSEQUENTLY SECTION 195 OF THE ACT WAS NOT APP LICABLE. EVEN SECTION 9 OF THE ACT IS NOT APPLICABLE AS THE AMOUNT RECEIVED BY BOTH THE NON RESIDENCE WAS NEITHER ROYALTY NOR FEES FOR TECHNICAL SERVICES AS ALLEGED BY THE ASSESSING OFFICER. THE PAYMENTS WERE BUSINESS PROVIDES OF BO TH THE NON-RESIDENT ASSESSEES AND AS PER ARTICLE 7 OF THE DTAA BETWEEN INDIA AND USA, BUSINESS PROFIT SHALL BE TAXABLE ONLY IN THE CONTRACTING STA TE UNLESS THE ENTERPRISE CARRIES ON BUSINESS IN THE OTHER CONTACTING STATES THROUGH A PERMANENT ESTABLISHMENT SITUATION THEREIN. BOTH THE NON-RESIDENT ASSESSEE S EARN THEIR INCOME FROM THE ASSESSEE COMPANY AS THEIR BUSINESS INCOME OUTSIDE I NDIA THEY CARRYING GIVEN ANY BUSINESS IN INDIA THROUGH A PERMANENT ESTABLISH MENT AND THUS THEIR INCOME FROM THE ASSESSEE COMPANY WAS COVERED BY ART ICLE 7 AND WAS TAXABLE IN THEIR RESPECTIVE CONTRACTING STATES AND NOT IN INDI A. THE LD. AR SUBMITTED THAT AS PER PROVISIONS OF SECTION 90(2) PROVISIONS OF DT AA SHALL BE APPLICABLE WITH REGARD TO APPLICABILITY IN THE HANDS OF NON-RESIDEN T IN AS HELD BY THE APEX COURT IN AZADI BACHAO ANDOLAN 263 ITR 706 ACCORDING TO WHICH THE PROVISIONS OF DTAA OVER RIGHTS INCOME TAX IN ANY CASES WHERE T HE DTAA IS BENEFICIAL TO 5 ITA NO. 715/DEL/2016 NON RESIDENCE. THE LD. AR RELIED UPON THE FOLLOWIN G JUDICIAL DECISIONS (I) GAMA INDUSTRIES COIMBATUR LTD. VS. CIT (2012) 5 4 SOT 104 (CHE. TRI.) (II) GRASIM INDUSTRIES LTD. & ORS VS. CIT(A) (2011 ) 332 ITR 276 (II) ACIT VS. PARADIGIM GEO PHYSICAL PVT. LTD. (2 008) 11 DTR 174 (DEL. TRI.). 6. THE LD. AR FURTHER SUBMITTED THAT THE ASSESSING OFFICER WAS NOT CORRECT IN ATTRACTING PROVISIONS OF SECTION 9(1)(VII) BY TR EATING THE PAYMENT AS ROYALTY AND FEES FOR TECHNICAL SERVICES WHEREAS THE FACT WA S THAT IN THE PREVIOUS YEAR RELEVANT TO THE ASSESSMENT YEAR 2012-13 ONLY THE RE TAINER FEE AS PER THE AGREEMENT WAS PAID AND EVEN NO ORDER PROCUREMENT SE RVICES IN REAL TERMS WERE MATERIALIZED BY THE SAID NON-RESIDENT AND WHENEVER SUCH SERVICES WERE RENDERED IN FUTURE. SAME WILL FALL IN THE EXPLANAT ION CLAUSE OF SUB CLAUSE B OF CLAUSE (VII) OF SUB SECTION 1 OF SECTION 9 OF THE A CT ON THE GROUND THAT INCOME WILL BE FROM THE SOURCE OUTSIDE IN INDIA. BOTH THE NON-RESIDENT ASSESSEE DERIVED THEIR INCOME AS THEIR BUSINESS ACTIVITY AND HIS BUSINESS PROFIT ARTICLE 7 OF DTAA BETWEEN INDIA AND USA ALSO ARTICLE 7 OF DTA A BETWEEN INDIA AND BELGIUM WERE APPLICABLE TO DETERMINE AS TO WHERE BU SINESS INCOME WILL BE TAXABLE. THEREFORE, NONE OF THE PROVISIONS OF THE SECTION 9 OF THE ACT WILL BE APPLICABLE IN THE PRESENT CASE, BUSINESS INCOME CAN NOT BE TREATED AS FEES FOR TECHNICAL SERVICES AS ALLEGED BY THE ASSESSING OFFI CER. EVEN COMMISSION INCOME HAS ALSO BEEN CONSIDERED AS BUSINESS INCOME AS HELD BY AAR IN TELE SOFT PVT. LTD 267 ITR 725 RECENTLY CBDT HAS ISSUE D CIRCULAR NO. 4/15 DATED 26/3/2015 EMPHASIZING LEGISLATIVE INTENT WITH REGAR D TO SECTION 9 READ WITH SECTION 195 OF THE ACT. LEGISLATIVE INTEND IS VERY CLEAR AS TO SECTION 5 INCLUDING SUB SECTION 2 OF THE SECTION 5 WHEREIN IT IS CLEARL Y STATE THAT IF INCOME DOES NOT ACCRUE OR ARISE IN INDIA NOR IS IT RECEIVED IN INDI A INCOME IN THE HANDS OF NON- RESIDENT WILL NOT BE TAXABLE IN INDIA. IN SUCH A S ITUATION, NEITHER SECTION 9 IS ATTRACTED NOR SECTION 195 OF THE ACT. THEREFORE, T HE LD. AR SUBMITTED THAT NO TDS IS REQUIRED TO BE DEDUCTED ON THE PAYMENTS MADE TO NON RESIDENCE BY THE 6 ITA NO. 715/DEL/2016 ASSESSEE COMPANY AND THUS QUESTION OF DISALLOWANCE U/S 40(A)(IA) DOES NOT ARISE. 7. THE LD. DR SUBMITTED THAT THE CIT(A) AS WELL AS THE ASSESSING OFFICER WAS CORRECT IN MAKING ADDITION. THE LD. DR SUBMITT ED THAT IT IS EVIDENT FROM THE TERMS OF THE AGREEMENT THAT CONSULTING SERVICES ARE THE RUNNING THEME IN THE AGREEMENTS DRAWN UP WITH THE NON-RESIDENTS. THE SERVICES PROVIDED IS IN THE NATURE OF ADVISORY SERVICES BASED UPON THE SKIL LS OF THE NON-RESIDENT. THE AGREEMENTS CLEARLY ARE IN THE NATURE OF END TO END SERVICES BEGINNING WITH CONSULTING AND CONCLUDING WITH INVOICES BEING RAISE D BY THE ASSESSEE COMPANY ON THE IDENTIFIED CLIENTS. THE LD. DR FURTHER SUBMI TTED THAT IT IS ONLY AN EXERCISE IN SEMANTICS UNDER TAKEN BY THE ASSESSEE C OMPANY TO ESCAPE THE PROVISIONS OF SECTION 9(1)(VII) OF THE ACT WHICH IN CLUDES NATURE OF SUCH PAYMENTS AS FEES FOR TECHNICAL SERVICES OBLIGATING THE ASSESSEE TO DEDUCT TAX AS PER PROVISIONS FOR SECTION 195(1) OF THE ACT. IF IT WAS ONLY AN ORDER PROCUREMENT AGREEMENT, IT IS NOT UNDERSTOOD AS TO WHY PAYMENTS WERE MADE SUBJECT TO TDS AS APPLICABLE. THE LD. DR RELIED UPON THE DECISION OF HONBLE APEX COURT IN CASE OF GVK INDUSTRIES VS. ITO (2015) 54 TAXMANN.CO M 347 (SC) AS WELL AS THE DECISION OF THE HON'BLE SUPREME COURT IN CASE OF TR ANSMISSION CORPORATION OF AP LIMITED AND ANOTHER VS. CIT(A) (1999) 239 ITR 58 7. THE LD. DR ALSO RELIED ON THE INTENTION OF THE PARLIAMENT RELATING TO THE INSERTION AND AMENDMENT OF SECTION 9 & SECTION 195 OF THE ACT. 8. WE HAVE HEARD BOTH THE PARTIES AND PERUSED ALL T HE RELEVANT MATERIAL AVAILABLE ON RECORD. IT IS PERTINENT TO NOTE HERE T HAT IN CASE OF THE ASSESSEE COMPANY, TWO NON-RESIDENT FOREIGN COMPANIES, ONE BY THE NAME OF J2S INC, USA AND ANOTHER BY THE NAME OF NAVOS, BELGIUM WERE APPOINTED TO LOCATE FOREIGN BUYERS TO WHOM THE ASSESSEE COMPANY COULD S ALE ITS SERVICES. THUS, BOTH THE FOREIGN COMPANIES RENDERED ORDER PROCUREME NT SERVICES OUTSIDE INDIA WHICH IS THEIR BUSINESS ACTIVITY. INVOICES RECEIVE D FROM THE PARTIES ALSO SHOW THAT SERVICES RENDERED BY THEM WERE SALES PROCUREME NT SERVICES AND NOT FEES 7 ITA NO. 715/DEL/2016 FOR TECHNICAL SERVICES OR ROYALTIES. THE CONTENTION OF THE LD. DR THAT THE SERVICES PROVIDED IS IN THE NATURE OF ADVISORY SERV ICES BASED UPON THE SKILLS OF THE NON-RESIDENT, IS CONTRARY TO THE TERMS AND COND ITIONS OF THE AGREEMENTS. IN THE PREVIOUS YEAR RELEVANT TO THE ASSESSMENT YEAR 2 012-13 ONLY THE RETAINER FEE AS PER THE AGREEMENT WAS PAID AND NO ORDER PROCUREM ENT SERVICES IN REAL TERMS WERE MATERIALIZED BY THE SAID NON-RESIDENT. THUS, T HE EXPLANATION CLAUSE OF SECTION 9 (VII) OF THE ACT WILL NOT BE APPLICABLE O N THE GROUND THAT INCOME WAS FROM THE SOURCE OUTSIDE INDIA. BOTH THE NON-RESIDE NT ASSESSEE DERIVED THEIR INCOME AS THEIR BUSINESS ACTIVITY AND THEIR BUSINES S PROFIT IS DETERMINED UNDER ARTICLE 7 OF DTAA BETWEEN INDIA AND USA AS WELL AS FROM ARTICLE 7 OF DTAA BETWEEN INDIA AND BELGIUM AND WILL THEN DECIDE AS T O WHERE BUSINESS INCOME WILL BE TAXABLE. THEREFORE, NONE OF THE PROVISIONS OF THE SECTION 9 OF THE ACT WILL BE APPLICABLE IN THE PRESENT CASE, BUSINESS INCOME CANNOT BE TREATED AS FEES FOR TECHNICAL SERVICES AS HELD BY THE ASSESSING OFFICER . THEREFORE, THE ASSESSING OFFICER AS WELL AS CIT(A) WAS NOT CORRECT IN TREATI NG THE ORDER PROCUREMENT SERVICES RENDERED BY THE NON-RESIDENTS AND COMMISS ION/RETAINER FEE AS ROYALTY AND FEES FOR TECHNICAL SERVICES. THE DECISIONS OF T HE HONBLE APEX COURT RELIED UPON BY THE LD. DR ARE FACTUALLY DIFFERENT AS THE T RANSACTIONS WAS BETWEEN INDIA AND SWITZERLAND AND NOT BETWEEN TWO DIFFERENT NON-RESIDENT AS IS IN THE PRESENT CASE. THE ORDER OF THE CIT(A) IS SET ASIDE. THUS APPEAL OF THE ASSESSEE IS ALLOWED. 9. IN RESULT, APPEAL OF THE ASSESSEE IS ALLOWED. ORDER PRONOUNCED IN THE OPEN COURT ON 19 TH JUNE, 2019 . SD/- SD/- (R. K. PANDA) (SUCHITRA KAMBLE) ACCOUNTANT MEMBER JUDICIAL MEMBER DATED: 19/06/2019 R. NAHEED COPY FORWARDED TO: 8 ITA NO. 715/DEL/2016 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(APPEALS) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI DATE OF DICTATION 6 . 6 . 2 0 1 9 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 7 . 6 . 2 0 1 9 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 1 9 . 6 . 2 0 1 9 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT 1 9 . 6 . 2 0 1 9 DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 1 9 . 6 . 2 0 1 9 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
