Ganesh Ramakant Yadav, Latur V. Income-tax Officer, Ward - 2, Latur

ITA 78/PUN/2018

• Counselvise Citation: [2019] 118 COUNSELVISE.COM (IT) 5063 (ITAT-PUNE)
• Duration Of Justice: 1 year(s) 27 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 06-02-2019
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: SMC
• Next Hearing Date: 31-12-2018
• Assessment Year: 2010-2011
• Appeal Filed On: 10-01-2018
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Keywords: Unexplained investment; Corroborative evidences
• Section: 69

Judgement Text

- IN THE INCOME TAX APPELLATE TRIBUNAL SMC BENCH, P UNE BEFORE SHRI D. KARUNAKARA RAO, AM AND SHRI PARTHA SARATHI CHAUDHURY, JM / ITA NO.78/PUN/2018 / ASSESSMENT YEAR : 2010-11 MR. GANESH RAMAKANT YADAV, LAXMIRAMAN NIWAS, NATH NAGAR, VIVEKANAND CHOWK, LATUR-413 512 PAN : ADCPY 0474F ....... / APPELLANT ! / V/S. THE INCOME TAX OFFICER, WARD-2, LATUR. / RESPONDENT ASSESSEE BY : SHRI SUHAS BORA REVENUE BY : SHRI RAJESH GAWALI / DATE OF HEARING : 04.02.2019 / DATE OF PRONOUNCEMENT : 06.02.2019 ' / ORDER PER PARTHA SARATHI CHAUDHURY, JM : THIS APPEAL PREFERRED BY THE ASSESSEE EMANATES FROM TH E ORDER OF LD. CIT(APPEALS)-2, AURANGABAD DATED 16.10.2017 FOR THE ASSES SMENT YEAR 2010- 11 AS PER FOLLOWING GROUNDS OF APPEAL ON RECORD: THE APPELLANT WOULD LIKE TO OBJECT THE IMPUGNED ORD ER OF THE COMMISSIONER OF INCOME TAX APPEAL-2, AURANGABAD ON T HE FOLLOWING GROUNDS WHICH ARE PASSED WITHOUT PREJUDICE TO EACH OTHER ON THE FACTS AND IN LAW. 1. THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL-II), AURANGABAD HAS ERRED IN CONFIRMING THE ADDITION OF RS.9,17,693 /- WITHOUT APPRECIATING FACTS AND CIRCUMSTANCES OF THE CASE AN D WITHOUT CONSIDERING THE PROVISIONS OF LAW IN TRUE SENSE. 2 ITA NO. 78/PUN/2018 A.Y.2010-11 2. THE LEARNED COMMISSIONER OF INCOME TAX (APPEAL-II), AURANGABAD HAS ERRED IN ASSESSING THE INCOME OF THE ASSESSEE A T RS.7,77,160/- AS AN ADDITIONAL OF INCOME FROM OTHER SOURCES ON AC COUNT OF UNEXPLAINED INVESTMENT UNDER SECTION 69 OF INCOME T AX ACT, 1961 WITHOUT CONSIDERING LAW, FACTS AND CIRCUMSTANCES OF THE CASE. 3. WITHOUT PREJUDICE TO THE FOREGOING, THE LEARNED COM MISSIONER OF INCOME TAX (APPEAL-II), AURANGABAD HAS ERRED & MISU NDERSTOOD THE SUBSTANCE OVER FROM & GAMUT OF THE MATTER IN CONSID ERING THE AMOUNT OF LUMP-SUM FAMILY SETTLEMENT OF RS.5,00,000/- AS U NEXPLAINED INVESTMENT OF THE APPELLANT. 4. APPELLANT URGE HEREWITH THAT, ANY UNJUST IN THIS MA TTER WILL CAUSE IRREPARABLE LOSS OF APPELLANT. 5. THE APPELLANT CRAVES TO LEAVE OR ADD, AMEND OR ALTE R ANY OF THE GROUNDS FOR APPEAL. IN VIEW OF ALL THESE AND OTHER GROUNDS WHICH MAY BE PRODUCED DURING THE HEARING OF APPEAL, THE APPEA L MAY BE ALLOWED AND JUSTICE RENDERED. 2. AT THE TIME OF HEARING, THE LD. AR OF THE ASSESSEE SUB MITTED THAT HE IS NOT PRESSING THE GROUND NO.1. THEREFORE, GROUND NO.1 IN G ROUNDS OF APPEAL IS DISMISSED AS NOT PRESSED . 3. GROUND NOS. 4 AND 5 ARE GENERAL IN NATURE AND HENCE , REQUIRE NO ADJUDICATION. 4. GROUND NOS. 2 AND 3 RELATES TO THE SAME ISSUE WHICH NEEDS TO BE ADJUDICATED BEFORE US. 4.1 THE BRIEF FACTS IN THIS CASE ARE THAT DURING THE COURS E OF ASSESSMENT PROCEEDINGS, THE ASSESSING OFFICER NOTED THAT THE ASSESSE E HAS DEPOSITED AN AMOUNT OF RS.11,88,160/- ON VARIOUS DATES IN HIS SAVING BA NK ACCOUNT MAINTAINED WITH THE AXIS BANK, LATUR BRANCH. THE ASSESSEE EXPLAINED THAT CASH DEPOSITS BY STATING THAT THE SAME WAS MADE ON BE HALF OF HIS COUSIN BROTHER SHRI RAM MANOHAR DESHPANDE WHO WAS BEEN STAY ING WITH HIS FAMILY SINCE THE AGE OF 8 YEARS AFTER THE DEMISE OF HIS MOTHER. I T WAS STATED THAT THE ASSESSEE'S MATERNAL UNCLE HAD AGRICULTURAL LAND AT GAT NO.152, VILLAGE 3 ITA NO. 78/PUN/2018 A.Y.2010-11 MAHALANGRA, TALUQA CHAKUR, DIST.: LATUR. UPON ATTAINING MAJORITY HIS COUSIN BROTHER HAD SOLD THE ANCESTRAL AGRICULTURAL LAND VIDE REGIS TRY DEED NO.672/2010 AND 673/2010 DATED 19/03/2010 TO ONE SHR I SHIVAJI TUKARAM KALE FOR A CONSIDERATION OF RS.4,11,000/-. SIMULTANEOUSLY, THE FAMILY MEMBERS HAD COMPELLED THE ASSESSEE'S MATERNAL UNCLE I.E. T HE FATHER OF HIS COUSIN TO PART WITH A SUM OF RS.5,00,000/- AS A ONE-TIME FAMILY SETTLEMENT FOR THE BETTER AND PROPER LIVELIHOOD OF HIS COUSIN. SINCE HIS COUSIN DID NOT HAVE ANY BANK ACCOUNT IN HIS NAME AT THAT TIME, AND TILL T HE FINALIZATION OF THE DECISION ABOUT PROPER INVESTMENT FOR THE WELFARE OF H IS COUSIN, THE ASSESSEE HAD DEPOSITED THE SAID AMOUNT INCLUDING HIS OWN SAVINGS IN THE SAVING BANK ACCOUNT WITH AXIS BANK. IN ORDER TO VERIFY T HE FACTS, THE ASSESSING OFFICER EXAMINED SHRI MANOHAR BABURAO DESHPANDE , FATHER OF THE ASSESSEE'S COUSIN UNDER OATH. THE RELEVANT CONTENTS OF THE STATEMENT RECORDED UNDER OATH ARE GIVEN IN PARA-12 OF THE ASSESS MENT ORDER. THE ASSESSING OFFICER ALSO EXAMINED THE ASSESSEE'S COUSIN SHRI RAM MANOHAR DESHPANDE UNDER OATH. THE RELEVANT PORTIONS OF THE CONT ENT OF THIS STATEMENT RECORDED UNDER OATH ARE GIVEN IN PARA-13 OF THE ASSESS MENT ORDER. THE ASSESSING OFFICER WAS SATISFIED ABOUT THE SOURCE OF RS.4,11,00 0/- WHICH WAS DEPOSITED INTO THE BANK ACCOUNT OF THE ASSESSEE. HOWEVE R, IN RESPECT OF THE BALANCE AMOUNT, THE ASSESSING OFFICER WAS NOT CONVINCED WIT H THE ANSWER GIVEN BY THE ASSESSEE. THE ASSESSING OFFICER OBSERVED THAT IN THE ANSWER TO QUESTION NO.6, MANOHAR DESHPANDE HAS STATED THAT HE HAD GIVEN A SUM OF RS.2 LAKH IN 2009 AND RS.3 LAKH IN 2010 IN CASH. HE HAD NOT GIVEN THE EXACT DATE OF GIVING THE CASH. REFERRING TO THE STATEMENT EVEN BY SHRI MANOHAR DESHPANDE, THE ASSESSING OFFICER HELD THAT, IT CAN BE INFERRE D THAT SHRI MANOHAR DESHPANDE DID NOT HAVE THE SOURCE TO ADVANCE THE CASH OF RS.5 LAKH TO HIS SON SHRI RAM DESHPANDE. HE FURTHER NOTED THA T IN FAMILY SETTLEMENT, USUALLY THE CASH AMOUNT IS GIVEN IN A LUMP-SUM . HOWEVER, THE 4 ITA NO. 78/PUN/2018 A.Y.2010-11 ASSESSING OFFICER NOTED THAT THE CASH DEPOSITS IN THE ASS ESSEE'S BANK ACCOUNT ARE ON DIFFERENT DATES IN SMALL AMOUNTS LESS THAN RS.1 LAKH. HE NOTED THAT HAS SHRI RAM DESHPANDE RECEIVED THE CASH AND LUMP-SUM ON A PARTICULAR DATE FROM HIS FATHER THEN THE CASH DEPOSIT IN THE BANK A CCOUNT SHOULD HAVE ALSO BEEN MADE IN A LUMP-SUM ON THE SAME DATE OR NEAR THE DATE OF RECEIPT OF CASH. THEREFORE, HE DID NOT ACCEPT THE EXPLANATION OF THE ASSESSEE THAT ONE OF THE SOURCES OF CASH DEPOSITS IS THE CASH RECEIVED BY HIS COUSIN SHRI RAM DESHPANDE FROM HIS FATHER. THE ASSESSING OFFICER THEN RELIE D ON VARIOUS DECISIONS OF THE HONOURABLE COURTS TO HOLD THAT IN THE PR ESENT CASE THE ASSESSEE HAS NOT SUBMITTED ANY SATISFACTORY EXPLANATION AND EVIDENCES IN SUPPORT OF HIS EXPLANATION ABOUT THE NATURE AND SOURCE OF CASH DEPOSITS. UNDER THE CIRCUMSTANCES, THE ASSESSING OFFICER MADE AN AD DITION OF RS.7,77,160/- BY WAY OF CASH DEPOSITS IN THE ASSESSES BAN K U/S.69 OF THE ACT. 5. DURING THE COURSE OF APPELLATE PROCEEDINGS, VIDE SUBMISS ION DATED 01.04.2017, THE ASSESSEE STATED THAT HE HAD DISCLOSED ALL MATERIAL FACTS AND CIRCUMSTANCES OF THE TRANSACTION AND THE APPEAL. HE STA TED THAT THE ASSESSEE HAD BROUGHT ALL EVIDENCES ON RECORD WHICH INCLUDED THE ST ATEMENT RECORDED UNDER OATH OF SHRI RAM MANOHAR DESHPANDE AND SHRI MANO HAR B. DESHPANDE. IT WAS STATED THAT BOTH THESE PERSONS HAVE ACCEPTED TH E FACT THAT THE AMOUNT OF RS.5,00,000/- WAS GIVEN BY SHRI MANOHAR B. D ESHPANDE TO HIS SON SHRI RAM MANOHAR DESHPANDE. IT WAS FURTHER STATED THAT THE ASSESSEE HAD DEPOSITED CASH OF RS.2,77,160/- ON SEVERAL DATES OUT OF CASH WITHDRAWALS MADE FROM SAVING BANKS ACCOUNT. HENCE, IT WAS STATED TH AT THE ASSESSING OFFICER HAS MADE THE ADDITION OF RS. 7,77,160/- MERELY ON SURMISES AND CONJECTURES WITHOUT ANY SUPPORTING EVIDENCES. THE LD.CI T(APPEAL) AFTER 5 ITA NO. 78/PUN/2018 A.Y.2010-11 CONSIDERING THE FACTS OF THE CASE AND THE SUBMISSIONS OF T HE ASSESSEE HAS HELD AS FOLLOWS: 7. I HAVE GONE THROUGH THE FACTS OF THE CASE, THE A SSESSMENT ORDER AND THE SUBMISSION MADE BY THE ASSESSEE. I FIND THAT IN THE INSTANT CASE, EXCEPT FOR RELYING ON THE STATEMENT MADE BY SHRI RA M MANOHAR DESHPANDE AND SHRI MANOHAR B. DESHPANDE, NO EVIDENC ES HAS BEEN BROUGHT ON RECORD TO SUGGEST THAT SHRI MANOHAR B. D ESHPANDE HAS THE MEANS TO ADVANCE THE SUM OF RS.5,00,000/- TO SHRI R AM MANOHAR DESHPANDE. IN THIS CONTEXT THE ANSWERS OF SHRI MANO HAR B. DESHPANDE MADE IN THE COURSE OF ASSESSMENT BEFORE THE ASSESSI NG OFFICER IS ALSO OF IMPORTANCE. THE QUESTION AND ANSWER IS REPRODUCE D HEREUNDER: Q.8 WHAT IS THE SOURCE OF PAYMENTS MADE TO MR. RAM OF RS.2 LAK IN 2009 AND RS.3 LAKHS IN 2010. PLEASE PRODUCE THE BAN K PASS BOOK. ANS. RS.2 LAKHS WAS PAID-OUT OF PAST SAVINGS, SALE OF BUFFALO AND OUT OF SALE OF SOME JEWELRY. RS.3 LAKH WAS PAID WAS OUT OF SOME AGRICULTURAL PRODUCE RS.50,000/- EACH FROM MATERNAL UNCLE SHRI R AJENDRA PATIL & SHRI SUDHAKAR PATIL. RS.50,000/- EACH FROM MY SISTERS- S MT. MADHU RESIDING AT PARBHANI AND SMT. LALITA RESIDING AT GANGAKHED. HUSBAND OF SMT. MADHU CARRIES ON THE BUSINESS OF HOTEL AND HUSBAND OF SMT. LALITA CARRIED OUT THE BUSINESS OF CUTTING OF WOOD. RS.50, 000/- WERE OBTAINED FROM SHRI SANTOSH CHAWARE, SON-IN-LAW OF MY BROTHER . HE RESIDES AT GUNJETI AND HE IS AGRICULTURIST. RS.50,000/- OUT OF PAST SAVINGS. Q.9. PLEASE SUBMIT NECESSARY DOCUMENTARY EVIDENCES IN SUPPORT OF YOUR CLAIM THAT RS.2 LAKH AND RS.3 LAKH WERE PAID TO MR. RAM FROM THE SOURCES AS MENTIONED IN ANSWER TO QUESTION NO.8 ABO VE. ANS. I HAVE NO DOCUMENTARY EVIDENCE. THE ABOVE PERS ONS ARE MY RELATIVES AND THEY HAVE GIVEN THE AMOUNTS IN CASH O N ORAL REQUEST. 8. IT IS EVIDENT FROM THE STATEMENT GIVEN BY SHRI M ANOHAR B.DESHPANDE THAT APART FROM MAKING A BALD ORAL DECLARATION, NOT HING HAS BEEN PROVIDED IN SUPPORT OF THE STATEMENT THAT HE HAD IN DEED MADE THE PAYMENT OF RS.5,00,000/- TO HIS SON SHRI RAM MANOHA R DESHPANDE. SUCH A STATEMENT IS A SELF-SERVING ASSERTION WHICH DOES NOT HAVE ANY STATUS IN THE EYES OF LAW. WHERE AN ASSESSEE FAILS TO PROVE SATISFACTORILY THE SOURCE AND NATURE OF A CERTAIN AMOUNT OF CASH R ECEIVED DURING THE ACCOUNTING PERIOD, THE ONUS OF PROVING THE SOURCE O R A SUM OF MONEY BY THE ASSESSEE IS ON HIM. THE EXPLANATION SHOULD BE SATISFACTORY AND ANY FANTASTIC EXPLANATION CANNOT B E TAKEN INTO COGNIZANCE BY THE ASSESSING OFFICER IF IN HIS OPINI ON THE EXPLANATION DOES NOT PROVIDE AMPLE JUSTIFICATION AS REGARDS THE SOUR CE CLAIMED BY HIM. IN THE INSTANT CASE, A SATISFACTORY EXPLANATION ABOUT THE NATURE AND SOURCE OF RS.5,00,000/- DEPOSITED INTO THE BANK ACCOUNT OF THE ASSESSEE HAS NOT BEEN PROVIDED. HENCE, I HOLD THAT THE ASSESSEE HAS NOT BEEN ABLE TO PROVIDE ANY SATISFACTORY EXPLANATION AND EVIDENCE I N SUPPORT OR EXPLANATION ABOUT THE NATURE AND SOURCE OF THE CASH DEPOSITED. SIMILARLY, APART FROM STATING THAT THE AMOUNT OF RS.2,77,160/- WAS O UT OF CASH WITHDRAWALS SAVING BANK ACCOUNT, THE ASSESSEE HAS N OT PROVIDED ANY OTHER MATERIAL LIKE THE CASH FLOW STATEMENT OR CASH BOOK FOR THE YEAR, THE NATURE AND SIZE OF FAMILY, TOTAL INCOME OF THE ASSE SSEE FOR THE YEAR AND WITHDRAWALS FOR HOUSEHOLD PURPOSES, ETC. WHICH WOUL D PROVE THE BONA FIDE OF HIS CLAIM THAT THE AMOUNT OF RS.2,77,160/- REPRESENTED THE CASH WITHDRAWALS MADE EARLIER. HENCE, I HOLD THAT THE SO URCE OF RS.2,77,160/- HAD ALSO NOT BEEN ADEQUATELY EXPLAINED BY THE ASSES SEE. UNDER THESE CIRCUMSTANCES, I HAVE NO HESITATION IN HOLDING THAT THE ASSESSEE HAS NOT 6 ITA NO. 78/PUN/2018 A.Y.2010-11 BEEN ABLE TO SATISFACTORY EXPLAIN THE SOURCES AND N ATURE OF DEPOSITS TO THE EXTENT OF RS.7,77,160/- DEPOSITED BY HIM IN HIS SAVING BANK ACCOUNT DURING THE RELEVANT PREVIOUS YEAR. THEREFORE, I SUS TAIN THE ADDITI ON MADE BY THE ASSESSING OFFICER AND ALL THE GROUNDS OF A PPEAL ARE DISMISSED. 6. THAT BEING FURTHER AGGRIEVED BY THE FINDINGS OF THE L D. CIT(APPEALS), THE ASSESSEE PREFERRED APPEAL BEFORE US. 7. AT THE TIME OF HEARING, THE LD. AR OF THE ASSESSEE S UBMITTED DETAILS OF SOURCES OF CASH COLLECTED BY THE SHRI MANOHAR BABURAO DESHPANDE WHICH IS AS UNDER: DETAILS OF SOURCES OF CASH COLLECTED BY THE SHRI MA NOHAR BABURAO DESHPANDE. SR. NO. SOURCES OF CASH DEPOSITED OCCUPATION AMOUNTS (RS.) RELATION DATE OF RECEIPT 1 SHRI RAJENDRA SIDRAM PATIL AT POST TALGHAL, TQ. CHAKUR AGRICULTURIST 50,000/- MATERNAL UNCLE 26.03.2010 2 SHRI SUDHAKAR SIDRAM PATIL AT POST TALGHAL, TQ. CHAKUR AGRICULTURIST 50,000/- MATERNAL UNCLE 26.03.2010 3 SMT. MADHUMATI SAKHARAM RANER KHANDOBA BAZAR, PARBHANI, DIST. PARBHANI HOTEL BUSINESS OF SPOUSE 50,000/- SISTER 27.03.2010 4 SMT. LALITA SUDHAKAR KARALE, VAISHNAV GALLI, GANGAKHED, DIST. PARBHANI SAW MILL BUSINESS OF SPOUSE 50,000/- SISTER 27.03.2010 5 SHRI SANTOSH SUKHDEV CHAWARE, AT POST GUJETI TQ. AHMADPUR, DIST. LATUR AGRICULTURIST 50,000/- SON IN LAW OF BROTHER 28.03.2010 6 OUT OF PAST SAVINGS, SALE OF BUFFALO, SALE OF JEWELLERY AND AGRICULTURAL INCOME ETC. SELF 2,50,000/- SELF TIME TO TIME TOTAL 5,00,000 /- 7 ITA NO. 78/PUN/2018 A.Y.2010-11 ON THE BASIS OF ABOVE CHART, THE LD. AR OF THE ASSESS EE SUBMITTED THAT THE SOURCES OF CASH DEPOSITS ARE WELL EXPLAINED AND THERE FORE, ADDITION NEEDS TO BE DELETED. 8. PER CONTRA, THE LD. DR HAS PLACED RELIANCE ON THE OR DERS OF SUB- ORDINATE AUTHORITIES. 9. WE HAVE PERUSED THE CASE RECORDS AND HEARD RIVAL C ONTENTIONS. WE HAVE GIVEN THOUGHTFUL CONSIDERATION TO THE ENTIRE DOCUMENTARY EVIDENCES ON RECORD. SOURCES OF CASH DEPOSITS FROM PERSONS IN SR. NO.1, 2, 3, 4, AND 5 HAS BEEN EXPLAINED. SR. NO.1, 2 AND 5 ARE AGRICULTURIST AND THE Y HAVE GIVEN RS.50,000/- EACH WHEREAS SR. NO. 3 IS ENGAGED IN HOTEL BUS INESS OF SPOUSE AND SR. NO.4 IS ENGAGED IN SAW MILL BUSINESS OF SPOUSE AND T HEY HAVE ALSO GIVEN RS.50,000/-EACH. HOWEVER, WITH REGARD TO THE AMOU NT OF RS.2,50,000/- STATED TO BE OUT OF PAST SAVINGS, SALE OF BUFFALO, SALE OF JE WELRY AND AGRICULTURAL INCOME, IT IS NOT EXPLAINED AT ALL AND WE ARE N OT CONVINCED WITH THE SOURCES OF THE SAID DEPOSITS. THE REFORE, OUT OF TOTAL DEPOSIT OF RS. 5,00,000/-, WE ALLOW THE DEPOSIT UP TO RS.2,50,000/- AS E XPLAINED BY THE ASSESSEE, WHEREAS, WE CONFIRM THE REMAINING RS.2,50,000/- TO BE ADDED IN THE HANDS OF THE ASSESSEE. THE ASSESSING OFFICER IS DIRECTE D TO PROVIDE APPEAL EFFECT ACCORDINGLY. 10. IN THE RESULT, APPEAL OF THE ASSESSEE IS PARTLY ALLOWED. ORDER PRONOUNCED ON 06 TH DAY OF FEBRUARY, 2019. SD/- SD/- D. KARUNAKARA RAO PARTHA SARATHI CHAUDHURY ACCOUNTANT MEMBER JUDICIAL MEMBER / PUNE; / DATED : 06 TH FEBRUARY, 2019. SB 8 ITA NO. 78/PUN/2018 A.Y.2010-11 '#$%&'(' % / COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT. 2. / THE RESPONDENT. 3. THE CIT(APPEAL)-2, AURANGABAD. 4. THE PR. CIT-2, AURANGABAD. 5. '#$ %%&' , ( &' , - )*+ , / DR, ITAT, SMC BENCH, PUNE. 6. $,- ./ / GUARD FILE. // TRUE COPY // (0 / BY ORDER, %1 &+ / PRIVATE SECRETARY ( &' , / ITAT, PUNE. 9 ITA NO. 78/PUN/2018 A.Y.2010-11 DATE 1 DRAFT DICTATED ON 0 4 .0 2 .2019 SR.PS/PS 2 DRAFT PLACED BEFORE AUTHOR 05 .0 2 .201 9 SR.PS/PS 3 DRAFT PROPOSED AND PLACED BEFORE THE SECOND MEMBER JM/AM 4 DRAFT DISCUSSED/APPROVED BY SECOND MEMBER AM/JM 5 APPROVED DRAFT COMES TO THE SR. PS/PS SR.PS/PS 6 KEPT FOR PRONOUNCEMENT ON SR.PS/PS 7 DATE OF UPLOADING OF ORDER SR.PS/PS 8 FILE SENT TO BENCH CLERK SR.PS/PS 9 DATE ON WHICH THE FILE GOES TO THE HEAD CLERK 10 DATE ON WHICH FILE GOES TO THE A.R 11 DATE OF DISPATCH OF ORDER