Shri Pranay N. Vora, Bhavnagar V. The Income Tax Officer, Ward-1(3), Bhavnagar

ITA 782/AHD/2017

• Counselvise Citation: [2018] 125 COUNSELVISE.COM (IT) 2401 (ITAT-AHMEDABAD)
• Duration Of Justice: 1 year(s) 5 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 30-08-2018
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2012-2013
• Appeal Filed On: 30-03-2017
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: VIKRAM C S SHARMA
• Assessee Lawyers: ADITY SHETH
• Keywords: Sale consideration of property below Jantri Value; Capital asset
• Section: 143(3); 50C

Judgement Text

, SMC IN THE INCOME TAX APPELLATE TRIBUNAL SMC BENCH, AHMEDABAD BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND MS. MADHUMITA ROY, JUDICIAL MEMBER ITA NO. 782/AHD/2017 / ASSESSMENT YEAR: 2012-13 PRANAY N VORA, PLOT NO. 1018, BC-2, B/H. SHANTINATH APARTMENT, NEAR VIDARBHA AKHADA, DAWN, BHAVNAGAR PAN NO. ACFPV 5190 H VS. INCOME TAX OFFICER, WARD-1(3), BHAVNAGAR / (APPELLANT) / (RESPONDENT) ASSESSEE BY : MS. ADITY SHETH, AR REVENUE BY : SHRI VIKRAM C.S. SHARMA, SR DR ! / DATE OF HEARING : 29.08.2018 / DATE OF PRONOUNCEMENT : 30.08.2018 / O R D E R PER MS. MADHUMITA ROY, JUDICIAL MEMBER: THE INSTANT APPEAL HAS BEEN FILED BY THE ASSESSEE A GAINST THE ORDER DATED 30.01.2017 PASSED BY THE LEARNED COMMISSIONER OF IN COME-TAX (APPEALS)-6, AHMEDABAD (HEREINAFTER REFERRED TO AS CIT(A)), AR ISING OUT OF THE ORDER DATED 23.03.2015 PASSED BY THE INCOME TAX OFFICER, WARD-1 (3), BHAVNAGAR UNDER SECTION 143(3) OF THE INCOME-TAX ACT, 1961(HEREINAF TER REFERRED TO AS 'THE ACT') FOR THE ASSESSMENT YEAR 2012-13. 2. THE GRIEVANCES RAISED BY THE ASSESSEE IN THIS AP PEAL ARE AGAINST THE ORDER OF THE CIT(A) (I) IN CONFIRMING THE ACTION OF THE ASSESSING OFFICER IN MAKING AN ADDITION OF RS.28,37,120/- U/S. 50C OF THE ACT, (II ) IN CONFIRMING THE ADOPTION OF RS.41,68,600/- AS THE FULL VALUE OF SALE CONSIDERAT ION FOR EACH OF THE TWO PLOTS U/S. 50C OF THE ACT AS AGAINST ACTUAL SALE CONSIDER ATION OF RS.27,50,000/- FOR EACH PLOT AS PER MARKET PRICE AND (III) IN UPHOLDIN G THE ACTION OF THE ASSESSING OFFICER OF NOT REFERRING THE MATTER TO THE DVO U/S 50C OF THE ACT. 2 ITA NO.782/AHD/2017 PRANAY N VORA VS. ITO AY : 2012-13 3. THE BRIEF FACTS OF THE CASE ARE THAT, DURING THE ASSESSMENT PROCEEDINGS, ON VERIFICATION OF RECORD OF THE ASSESSEE IT REVEALED THAT THE ASSESSEE HAS SOLD TWO OPEN PLOTS SITUATED AT ISCON MEGACITY, BHAVNAGAR AT A SALE CONSIDERATION OF RS.27,50,000/- FOR EACH PLOT BY AND UNDER THE REGIS TERED SALE DEED BEARING NOS. 216/2012 AND 217/2012 RESPECTIVELY ON 21.01.2012. IT WAS FURTHER REVEALED FROM THE SALE DEED THAT, ON THESE TRANSFERS, AN AMO UNT OF RS.2,04,300/- WAS PAID AS STAMP DUTY IN EACH CASE. ACCORDINGLY, AS PER TH E STAMP DUTY VALUATION, THE VALUATION OF EACH OF THESE PLOTS COMES TO RS.41,68, 800/-. THEREFORE, THE SALE CONSIDERATION IS LESS THAN THE VALUE ADOPTED BY THE STAMP VALUATION AUTHORITY FOR THE PURPOSE OF STAMP DUTY; AS A RESULT WHEREOF, A SHOW-CAUSE NOTICE WAS ISSUED. THE ASSESSEE FILED HIS REPLY ALONG WITH THE VALUATION ISSUED BY THE SUB- REGISTRAR, BHAVNAGAR-1. HOWEVER, THE SUBMISSION FU RNISHED BY THE ASSESSEE WAS NOT TENABLE ACCORDING TO THE ASSESSING OFFICER. THE CONTENTION MADE BY THE ASSESSEE THAT THE SALE CONSIDERATION RECEIVED BY HI M FOR THE SALE OF PLOTS WAS IN ACCORDANCE WITH THE PREVAILING MARKET RATE AS WELL AS THE VALUE DETERMINED BY THE VALUATION AUTHORITY WAS NOT ACCEPTED BY THE LEA RNED ASSESSING OFFICER. FURTHER THAT THE STAMP DUTY PAID BY THE ASSESSEE FO R THE PURPOSE OF REGISTRATION OF SALE DEED WAS OF THE HIGHER VALUE AS COMPARED TO THE PREVAILING STAMP VALUATION DUTY AT THE TIME OF UNDERTAKING THE TRANS ACTION OF SALE, AS SUBMITTED BY THE ASSESSEE, WAS ALSO NOT ACCEPTED BY THE LEARN ED ASSESSING OFFICER. ON PERUSAL OF THE CALCULATION SHEET, THE ASSESSING OFF ICER CAME TO THE CONCLUSION THAT THE STAMP VALUATION AUTHORITY HAS CONSIDERED T HE JANTRI RATE @ 11500/- SQ. MTR. AND THE VALUE OF EACH PLOT ASSESSED AT RS.41,6 8,800/-. ACCORDING TO THE LEARNED ASSESSING OFFICER, THE FOLLOWING CONDITIONS PROVIDED UNDER SECTION 50C HAVE BEEN FULFILLED:- 1. THERE IS A TRANSFER OF LAND OR BUILDING OR BOTH. 2. THE ASSET MAY BE LONG TERM CAPITAL ASSET OR SHORT T ERM CAPITAL ASSET. 3. IT MAY BE DEPRECIABLE OR NON-DEPRECIABLE ASSET. 4. THE SALE CONSIDERATION IS LESS THAN VALUE ADOPTED B Y STAMP DUTY AUTHORITY. 3 ITA NO.782/AHD/2017 PRANAY N VORA VS. ITO AY : 2012-13 AND, THEREFORE, THE VALUATION DONE BY THE STAMP VAL UATION AUTHORITY HAS BEEN TAKEN AS FULL VALUE CONSIDERATION RECEIVED BY THE ASSESSEE, I.E. RS.41,68,800/- FOR EACH PLOT. ULTIMATELY, THE SHOR T TERM CAPITAL GAIN (STCG) HAS BEEN ASSESSED BY THE ASSESSING OFFICER TO THE T UNE OF RS.28,78,120/- FOR TWO PLOTS; WHEREAS, THE ASSESSEE HAS SHOWN RS.41,000/- AS THE SHORT TERM CAPITAL GAIN FROM THE TRANSFER OF THESE TWO PLOTS. THE DIF FERENCE AMOUNT OF RS.28,37,120/- HAS BEEN ADDED TO THE TOTAL INCOME O F THE ASSESSEE AND THE INCOME OF THE ASSESSEE HAS BEEN ASSESSED AT RS.40,5 2,430/-. 4. THE LEARNED COUNSEL FOR THE ASSESSEE, AT THE TIM E OF HEARING OF THE INSTANT APPEAL, ADDRESSED US ON THE ISSUE THAT WHEN THERE I S A DISPUTE REGARDING THE JANTRI VALUE AND THE PAYMENT MADE TO THE ASSESSEE, THEN THE MATTER OUGHT TO HAVE BEEN REFERRED TO THE DVO BY THE ASSESSING OFFI CER EVEN IF IT IS NOT ASKED FOR BY THE ASSESSEE. FURTHER THAT THE SAME HAS ALSO NOT BEEN TAKEN CARE OF BY THE FIRST APPELLATE AUTHORITY BEING LEARNED CIT(A). HE , THEREFORE, PRAYS FOR REFERRING THE MATTER TO THE DVO FOR MAKING ASSESSME NT UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE. HE RELIES UPON THE JUDG MENTS OF THE CO-ORDINATE BENCH OF THIS TRIBUNAL IN THE FOLLOWING CASES:- (I) TARUN MANMOHAN GARG VS. DCIT IN ITA NO.3208/AHD/201 5 FOR AY 2011-12, ORDER DATED 22.08.2017 (II) SARITA SANGAM SOCIETY VS. DCIT IN ITA NO.3562/AHD/2 016 FOR AY 2013-14, ORDER DATED 16.05.2018 (III) MUKESH NATVARLAL NAGRAWALA VS. ACIT IN ITA NO.592/A HD/2014 FOR AY 2010-11 5. LEARNED DEPARTMENTAL REPRESENTATIVE, ON THE OTHE R HAND, RELIES UPON THE ORDERS PASSED BY THE AUTHORITIES BELOW. 6. WE HAVE HEARD THE LEARNED REPRESENTATIVES OF THE PARTIES AND PERUSED THE MATERIAL AVAILABLE ON RECORD. WE FIND THAT IT IS MANDATORY ON THE PART OF THE ASSESSING OFFICER TO REFER THE MATTER TO THE DVO, E VEN IF IT IS NOT ASKED BY THE 4 ITA NO.782/AHD/2017 PRANAY N VORA VS. ITO AY : 2012-13 ASSESSEE BEFORE THE AUTHORITIES BELOW, BEFORE COMPU TATION OF CAPITAL GAINS UNDER THE FACTS AND CIRCUMSTANCES OF THE CASE IN HAND AS DECIDED BY NUMBER OF JUDGMENTS PASSED BY THE CO-ORDINATE BENCH OF THIS T RIBUNAL, THE HONBLE JURISDICTIONAL HIGH COURT AS WELL AS HONBLE HIGH C OURT OF CALCUTTA, WHICH THE ASSESSING OFFICER HAS FAILED TO DO. THE RELEVANT P ORTION OF THE JUDGMENTS PASSED BY THE CO-ORDINATE BENCH OF THIS TRIBUNAL, A S RELIED UPON BY THE REPRESENTATIVE OF THE ASSESSEE, ARE AS FOLLOWS:- (I) TARUN MANMOHAN GARG VS. DCIT IN ITA NO.3208/AHD/201 5 FOR AY 2011-12, ORDER DATED 22.08.2017 2. LEARNED REPRESENTATIVES FAIRLY AGREE THAT WHATE VER WE DECIDE IN ITA NO.3207/AHD/2015 IN THE CASE OF MANMOHAN RAJARAM GA RG VS. DCIT FOR THE ASSESSMENT YEAR 2011-12, WHICH WE HAD HEARD ALONG W ITH THIS APPEAL, WILL APPLY MUTATIS MUTANDIS FOR THIS APPEAL AS WELL, AS THE ISSUE RAISED IN THIS APPEAL IS IDENTICAL TO THAT OF ITA NO.3207/AHD/2015 IN THE CASE OF MANMOHAN RAJARAM GARG FOR THE ASSESSMENT YEAR 2011- 12. VIDE MY ORDER OF EVEN DATE, I HAVE ALLOWED THE SAME ISSUE FOR STATIS TICAL PURPOSES IN THE CASE OF MANMOHAN RAJARAM GARG IN ITA NO.3207/AHD/2015, AND THE SAME RESULT MUST FOLLOW HERE AS WELL. IN MY SAID ORDER, I HAVE, INTER ALIA, OBSERVED AS FOLLOWS: 2. WHEN THIS APPEAL WAS CALLED OUT FOR HEARING, LE ARNED COUNSEL FOR THE ASSESSEE INVITED OUR ATTENTION TO ORDER DATED 31ST AUGUST 2016, PASSED BY THIS TRIBUNAL, IN THE CASE OF NARENDRA DAHYABHAI PA TEL VS. ITO IN ITA NO.2087/AHD/2013, BY WHICH THE ISSUE IN APPEAL BEFO RE ME IS SAID TO BE COVERED. LEARNED COUNSEL SUBMITS THAT THE SHORT ISS UE REQUIRING OUR ADJUDICATION IN THIS CASE IS WHETHER OR NOT, IN THE ABSENCE OF A SPECIFIC REQUEST MADE BY THE ASSESSEE DURING THE ASSESSMENT PROCEEDINGS FOR REFERENCE BEING MADE TO THE DVO UNDER SECTION 50C, SUCH REFERENCE COULD BE DIRECTED BY THE APPELLATE AUTHORITIES. IN THIS C ONNECTION, SHE INVITES MY ATTENTION TO THE FOLLOWING OBSERVATIONS MADE BY THE TRIBUNAL IN THE CASE OF NARENDRA DAHYABHAI PATEL VS. ITO (SUPRA). 2. IT IS A CASE IN WHICH THE ASSESSING OFFICER HAS ADOPTED STAMP DUTY VALUATION OF THE PROPERTY SOLD, FOR COMPUTATION OF CAPITAL GAINS, UNDER SECTION 50C OF THE INCOME TAX ACT, 1961. IN APPEAL BEFORE THE LEARNED CIT(A), THE ASSESSEES CONTENTION WAS THAT DESPITE HIS REQUEST, THE MATTER WAS NOT REFERRED TO DVO UNDER SECTION 50C(2) BUT THE APPEAL WAS TURNED DOWN ON THE GROUND THAT ASSESSEE COULD N OT SUBSTANTIATE HIS CLAIM OF HAVING MADE SUCH A REQUEST IN THE COUR SE OF ASSESSMENT 5 ITA NO.782/AHD/2017 PRANAY N VORA VS. ITO AY : 2012-13 PROCEEDINGS. THE ASSESSEE IS NOT SATISFIED AND IS I N FURTHER APPEAL BEFORE ME. 3. I HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIAL ON RECORD AND DULY CONSIDERED FACTS OF THE CASE IN THE LIGHT OF THE APPLICABLE LEGAL POSITION. 4. I FIND THAT, AS HELD BY HONBLE CALCUTTA HIGH CO URT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT [(2015) 372 ITR 83 (CAL ], EVEN IN THE ABSENCE OF SPECIFIC REQUEST FROM THE ASSESSEE, THE ASSESSING OFFICER HAS TO GIVE AN OPTION TO THE ASSESSEE TO FOLLOW THE COU RSE PROVIDED BY LAW UNDER SECTION 50C(2). I, THEREFORE, UPHOLD THE GRIE VANCE OF THE ASSESSEE, AND REMIT THE MATTER TO THE FILE OF THE ASSESSING O FFICER FOR ADJUDICATION DE NOVO AFTER REFERRING THE MATTER TO THE DVO UNDER SECTION 50C(2). 3. LEARNED COUNSEL SUBMITS THAT AS THE APPEAL CAN B E DISPOSED OF ON THE ABOVE SHORT GROUND, IT IS NOT REALLY NECESSARY TO D EAL WITH OTHER ASPECTS OF THE MATTER. SHE THUS URGES ME TO REMIT THE MATTER T O THE FILE OF ASSESSING OFFICER WITH THE DIRECTION TO REFER THE MATTER TO T HE DVO UNDER SECTION 50C(2). 4. LEARNED DEPARTMENTAL REPRESENTATIVE DOES NOT DIS PUTE THE FACT THAT THE ISSUE IS SQUARELY COVERED BY THE AFORESAID DECISION OF THE TRIBUNAL BUT POINTS OUT THAT NO SUCH REQUEST FOR REFERENCE TO DV O WAS MADE BY THE ASSESSEE IN THE COURSE OF ASSESSMENT PROCEEDINGS. H E THUS RELIES UPON THE ORDERS OF THE AUTHORITIES BELOW. 5. I HAVE HEARD THE RIVAL SUBMISSIONS, PERUSED THE MATERIAL ON RECORD AND DULY CONSIDERED FACTS OF THE CASE IN THE LIGHT OF T HE APPLICABLE LEGAL POSITION. I FIND THAT AS NOTED BY THE TRIBUNAL IN T HE CASE OF NARENDRA DAHYABHAI PATEL VS. ITO (SUPRA) THE LAW IS NOW WELL SETTLED THAT EVEN IN THE ABSENCE OF A SPECIFIC REQUEST FROM THE ASSESSEE , THE A.O. HAS TO GIVE AN OPTION TO THE ASSESSEE TO FOLLOW THE COURSE PROVIDE D BY LAW UNDER SECTION 50C(2). THERE IS A DIRECT DECISION TO THIS EFFECT B Y HONBLE CALCUTTA HIGH COURT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT [( 2015) 372 ITR 83 (CAL]. NO JUDICIAL PRECEDENCE TO THE CONTRARY HAS B EEN BROUGHT TO MY NOTICE. RESPECTFULLY FOLLOWING THE ESTEEMED VIEW OF THE HONBLE CALCUTTA HIGH COURT IN THE CASE OF SUNIL KUMAR AGARWAL VS. C IT (SUPRA), I UPHOLD THE PLEA OF THE ASSESSEE AND REMIT THE MATTER TO TH E FILE OF ASSESSING OFFICER FOR ADJUDICATION DENOVO AFTER REFERRING THE MATTER TO THE DVO UNDER SECTION 50C(2). AS THE MATTER HAS BEEN REMITTED TO THE FILE OF ASSESSING OFFICER WITH THE ABOVE DIRECTIONS, IT IS NOT REALLY NECESSARY TO DEAL WITH OTHER ASPECTS OF THE MATTER. 6 ITA NO.782/AHD/2017 PRANAY N VORA VS. ITO AY : 2012-13 3. RESPECTFULLY FOLLOWING THE VIEWS SO TAKEN BY ME IN THE CASE OF MANMOHAN RAJARAM GARG VS. DCIT (ITA NO.3207/AHD/2015) FOR AS SESSMENT YEAR 2011- 12, THE ISSUE RAISED BY THE ASSESSEE IN THIS APPEAL IS ALSO ALLOWED FOR STATISTICAL PURPOSES. (II) SARITA SANGAM SOCIETY VS. DCIT IN ITA NO.3562/AHD/2 016 FOR AY 2013-14, ORDER DATED 16.05.2018 5. AS A PLAIN READING OF SECTION 50C(2) SHOWS, WHE N THE ASSESSEE CLAIMS BEFORE ANY ASSESSING OFFICER THAT THE VALUE ADOPTED OR ASSESSED OR ASSESSABLE BY THE STAMP VALUATION AUTHORITY EXCEEDS THE FAIR M ARKET VALUE OF THE PROPERTY, THE ASSESSING OFFICER MAY REFER THE VALU ATION OF THE PROPERTY TO THE DEPARTMENTAL VALUATION OFFICER. CLEARLY, THEREF ORE, A SPECIFIC REQUEST FOR REFERENCE TO THE DEPARTMENTAL VALUATION OFFICER IS NOT AT ALL REQUIRED TO BE MADE BY THE ASSESSEE, AND ALL THAT IS REQUIRED TO I NVOKE THE REFERENCE TO THE DEPARTMENTAL VALUATION OFFICER IS A DISPUTE BEING R AISED ON VALUATION AS PER STAMP DUTY VALUATION AUTHORITY. IN ANY EVENT, AS IS THE SETTLED LEGAL POSITION IN THE LIGHT OF HONBLE CALCUTTA HIGH COURTS JUDGM ENT IN THE CASE OF SUNIL KUMAR AGARWAL VS. CIT (GA NO.3686/2013; JUDGEMENT D ATED 13TH MARCH 2014) EVEN IN A CASE WHERE NO SUCH PRAYER IS MADE BY THE ASSESSEE THE ASSESSING OFFICER, DISCHARGING A QUASI JUDICIAL FUN CTION HAS THE BOUNDEN DUTY TO ACT FAIRLY AND TO GIVE A FAIR TREATMENT BY GIVING HIM AN OPTION TO FOLLOW THE COURSE PROVIDED BY THE LAW. IN THE LIG HT OF THESE DISCUSSIONS, AS ALSO BEARING IN MIND ENTIRETY OF THE CASE, WE DEEM IT FIT AND PROPER TO REMIT THE MATTER TO THE FILE OF THE ASSESSING OFFICER WIT H A DIRECTION TO REFER THE VALUATION OF PROPERTY TO THE DEPARTMENTAL VALUATION OFFICER, AND TO FRAME THE FRESH ASSESSMENT IN THE LIGHT OF, INTER ALIA, D EPARTMENTAL VALUATION OFFICERS REPORT, IN ACCORDANCE WITH THE LAW, AFTER AFFORDING AN OPPORTUNITY OF HEARING TO THE ASSESSEE AND BY WAY OF A SPEAKING OR DER. THE MATTER THUS STANDS RESTORED TO THE FILE OF THE ASSESSING OFFICE R IN THE TERMS INDICATED ABOVE. 6. AS WE PART WITH THE MATTER, WE MAY ADD THAT THER E IS APPARENTLY ALSO A DISPUTE WITH RESPECT OF THE POINT OF TIME AS TO WHI CH STAMP DUTY VALUATION IS TO BE ADOPTED - AT THE POINT OF TIME WHEN AGREEMENT TO SELL WAS FINALIZED OR WHEN SALE DEED WAS REGISTERED. THIS ASPECT OF THE M ATTER IS NOT REALLY RELEVANT AT PRESENT AS THE MATTER STANDS RESTORED TO THE ASS ESSING OFFICER FOR THE PURPOSE OF DEPARTMENTAL VALUATION OFFICERS VALUATI ON. HOWEVER, SUFFICE TO ADD, WHILE EXAMINING THIS ASPECT OF THE MATTER, THE ASSESSING OFFICER WILL TAKE INTO ACCOUNT BINDING JUDICIAL PRECEDENTS ON THE ISS UE, INCLUDING IN THE CASE OF DHARMASHI BHAI SONANI VS. ACIT [(2016) 161 ITD 627 (AHD)]. WE LEAVE IT THAT FOR THE TIME BEING. 7. CONSIDERING THE ENTIRE ASPECT OF THE MATTER AND RESPECTFULLY FOLLOWING THE JUDGMENTS PASSED BY THE CO-ORDINATE BENCH OF THIS T RIBUNAL (SUPRA), WE ARE OF 7 ITA NO.782/AHD/2017 PRANAY N VORA VS. ITO AY : 2012-13 THE VIEW THAT THE MATTER BE REMITTED TO THE FILE OF THE ASSESSING OFFICER FOR ADJUDICATION OF THE SAME DE NOVO UPON MAKING REFERENCE TO THE DVO AND TO COMPLETE THE ASSESSMENT ON THE BASIS OF THE VALUATI ON SO RECEIVED FROM THE DVO. WE PASS ORDERS ACCORDINGLY AND DIRECT THE ASS ESSING OFFICER TO DECIDE THE MATTER AFRESH ON THE BASIS OF THE VALUATION TO BE MADE BY THE DVO BY PASSING A SPEAKING ORDER IN ACCORDANCE WITH LAW UPO N GIVING A REASONABLE OPPORTUNITY OF HEARING TO THE ASSESSEE. 8. IN THE RESULT, THE APPEAL OF THE ASSESSEE IS ALL OWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE COURT ON 30 TH AUGUST, 2018 AT AHMEDABAD. SD/- SD/- ( WASEEM AHMED ) ACCOUNTANT MEMBER ( MS. MADHUMITA ROY) JUDICIAL MEMBER AHMEDABAD; DATED 30 / 08/2018 **BT ! &'( )(/ COPY OF THE ORDER FORWARDED TO : 1. / THE APPELLANT 2. / THE RESPONDENT. 3. , / CONCERNED CIT 4. , ) ( / THE CIT(A)- 5. ( && , , /DR,ITAT, AHMEDABAD, 6. 5 / GUARD FILE. / BY ORDER, TRUE COPY (ASSTT. REGISTRAR) ITAT, AHMEDABAD 1. DATE OF DICTATION 29.08.2018.. 1. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER : .. 29.08.2018 2. OTHER MEMBER30.08.2018.. 3. DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR.P. S./P.S30.08.2018. 4. DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE D ICTATING MEMBER FOR PRONOUNCEMENT30.08.2018.. 5. DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR.P .S./P.S30.08.2018 6. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK30.0 8.2018 7. DATE ON WHICH THE FILE GOES TO THE HEAD CLERK 8. THE DATE ON WHICH THE FILE GOES TO THE ASSISTANT RE GISTRAR FOR SIGNATURE ON THE ORDER 9. DATE OF DESPATCH OF THE ORDER