Capital Infra Projects Pvt. Ltd., Delhi V. DCIT, Central Circle, Noida

ITA 928/DEL/2019

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 7214 (ITAT-DELHI)
• Duration Of Justice: 1 year(s) 6 month(s) 28 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 04-09-2020
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: B
• Assessment Year: 2014-2015
• Appeal Filed On: 06-02-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: NIDHI SRIVASTAVA
• Keywords: Unexplained cash credit; Search and seizure; Source of fund; Accommodation entries; Rule 8D
• Section: 143(3); 14A; 133(6); 13; 131; 68; 132

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI B BEN CH, NEW DELHI [THROUGH VIDEO CONFERENCE] BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, AND SHRI KULDIP SINGH, JUDICIAL MEM BER ITA NO. 927 & 928/DEL/2019 [ASSESSMENT YEAR: 2013-14 & 2014-15] CAPITAL INFRA PROJECTS PVT LTD VS THE DY. C.I.T C/O M/S RRA TAX INDIA CENTRAL CIRCLE D -28, SOUTH EXTENSION NEW DELHI. PART 1, NEW DELHI. PAN : AAECC 0093 J [APPELLANT] [RESPONDENT] DATE OF HEARING : 02.09.2020 DATE OF PRONOUNCEMENT : 04.09.2020 ASSESSEE BY : SHRI RAJIV KHANDELWAL, CA REVENUE BY : MS. NIDHI SRIVASTAVA, CIT- DR ORDER PER N.K. BILLAIYA, ACCOUNTANT MEMBER, THE ABOVE TWO APPEALS BY THE ASSESSEE ARE PREFERRE D AGAINST THE COMMON ORDER OF THE CIT(A) 4, KANPUR DATED 30.11. 2018 PERTAINING TO A.YS 2013-14 AND 2014-15. THE UNDERLYING FACTS IN I SSUES ARE IDENTICAL. THEREFORE, BOTH THESE APPEALS ARE DISPOSED OFF BY T HIS COMMON ORDER FOR THE SAKE OF CONVENIENCE AND BREVITY. 2. THE QUARREL IS IN RESPECT OF LOAN RECEIVED FROM M/S PABLA LEASING AND FINANCE PVT. LTD AMOUNTING TO RS. 3 CRORES IN E ACH A.Y TREATED BY THE ASSESSING OFFICER AS UNEXPLAINED CASH CREDIT AN D, ACCORDINGLY, ADDITIONS HAVE BEEN MADE UNDER SECTION 68 OF THE AC T. 3. THE REPRESENTATIVES OF BOTH THE SIDES WERE HEARD AT LENGTH, THE CASE RECORDS CAREFULLY PERUSED AND WITH THE ASSISTA NCE OF THE LD. COUNSEL, WE HAVE CONSIDERED THE DOCUMENTARY EVIDENC ES BROUGHT ON RECORD IN THE FORM OF PAPER BOOK IN LIGHT OF RULE 1 8(6) OF ITAT RULES AND HAVE ALSO PERUSED THE JUDICIAL DECISIONS RELIED UPON BY BOTH THE SIDES. 4. FACTS ON RECORD SHOW THAT A SEARCH AND SEIZURE O PERATION U/S 132 OF THE ACT WAS CONDUCTED ON 26.8.2015 ON THE PREMIS ES OF THE ASSESSEE COMPRISING IITL NIMBUS GROUP OF CASES. 5. FACTS FURTHER SHOW THAT THIS GROUP IS ENGAGED IN THE BUSINESS OF SALE OF FLATS IN THE TERRITORIAL AREA OF GHAZIABAD, DELHI AND NOIDA. THE APPELLANT COMPANY WAS ESTABLISHED ON 07.06.2010 WIT H ONLY TWO SHAREHOLDERS, NAMELY, NIMBUS PROJECTS LIMITED AND I ITL PROJECTS LIMITED, EACH HOLDING 50% OF THE SHARE. 6. DURING THE COURSE OF SCRUTINY ASSESSMENT PROCEED INGS, THE ASSESSING OFFICER NOTICED THAT THE ASSESSEE HAS TAK EN LOAN FROM PABLA LEASING AND FINANCE PVT. LTD AMOUNTING TO RUPEES 3 CRORES. THE ASSESSING OFFICER FOUND THAT THERE IS AN ENQUIRY RE PORT FROM THE INVESTIGATION UNIT, KOLKATA IN THE CASE OF SOME OF THE COMPANIES AND REPORT REVEALS THAT THE SAID COMPANIES HAVE BEEN US ED BY DIFFERENT ACCOMMODATION ENTRY OPERATORS TO FACILITATE ACCOMMO DATION ENTRIES IN DIFFERENT FORMS TO VARIOUS BENEFICIARY GROUPS. 7. ONE OF SUCH NAMED COMPANY IS PABLA LEASING AND F INANCE PVT. LTD. ACCORDING TO THE REPORT, THE ASSESSING OFFICER FOUND THAT PABLA LEASING AND FINANCE PVT. LTD HAS PROVIDED ACCOMMODA TION ENTRIES ON COMMISSION BASIS TO IITL NIMBUS GROUP OF COMPANIES. THE RELEVANT EXTRACT OF THE REPORT IS AS UNDER: THE DEPUTY DIRECTOR OF INCOME-TAX (INV.) - II 4 TH FOOR, A-2D SECTOR -21, NOIDA SIR. SUB:ENQUIRY REPORT FOR COMMISSION U/S 131{L){D) OF THE I.T.ACT 1961 IN RESPECT OF M/S. IITL-NIMBUS GROUP - MATTER READING REF: YOUR LETTER HAVING NO.DDIT(LNV.HI/ NOIDA/ NIMBUS /20L5-L6/190 DATED 14. 10 2015. KINDLY REFER TO THE ABOVE. A COMMISSION U/S. I31(L)(D) OF THE INCOME-TAX ACT. 1S61 DOTED 14/10/2015 WAS RECEIVED BY THIS OFFICE TO ENQ UIRE ABOUT THE GENUINENESS AND EXISTENCE OF THE FOLLOWING INVE STING COMPANIES IN CONNECTION WITH THE SEARCH CONDUCTED I N THE CASE OF NIMBUS GROUP. 1. M/S PABLA LEASING AND FINANCE PVT. LTD., 7 GRANT LANE, KOLKATA 2. M/S G:RI FINANCIAL SERVICES 3 VT LTD , 68 JESSORE ROAD. 3 ,J FLOOR, FLAT NO.314. KOLKATA 3. M/S INTELLECTUAL SECURITIES PVT. LTD., ROOM NO.4 ISA, 4 :H FLOOR, MARSHALL HOUSE, N.5. ROAD, KOLKATA-700001 FURTHER REQUEST WAS IR. 3 DE BY YOU TO CONDUCT ENQUIRIES IN RESPECT OF OTHER FOLLOWING COMPANIES: 1. M/S PADMA ESTATE PVT. LTD, OFFICE NO41SA,4 ,H FLOOR, MARSHAL HOUSE,33/1, N S ROAD KOLKATA-1 2. M/S. CINDYGOODJ & SUPPLY PVT LTD, OFFICE NO.418A, FLAOR, .M. ARSHAL HOUSE 53/1 N S ROAD, KOLKATA 3 M/S BHANDARI FINANCIAL SERVICES PVT LTD, 121; U .S. ROAD, 5 TH FLOOR ROOM NO - 59, KOLKATA 4. M/S. NIPPY TRADING PVT. LTD, 7A BENCH STREET, NEW WING. ROOM FIO.3G3, 3 ' FLOOR. 5. KAYPEE MERCANTILE PVT LIE. 37 SHAKESPEARE SARA NI, 4 I 'FLOOR, KOLKATA-17 ACCORDINGLY, SUMMONSES WERE ISSUED TO : THE PRINCIPAL OFFICER/DIRECTORS OR ALL THE ABOVE COMPANIES AND IT WAS FOUND THAT NONE OF THE ABOVE COMPANIES EXCEPT BHAND ARI FINANCIAL SERVICES PVT LTD AND NIPPY VS. LTD. EXIST ED AT THEIR GIVEN ADDRESSES. IT WAS MENTIONED ON THE ADDRESS A T OFFICE NO 418A, 4 TH FLOOR, MARSHAL HOUSE 33/1, KOLKATA-70C031 THAT THE COMPANIES OF THAT ADDRESS HAVE BEEN SHIFTE D TC E ADDRESS ST; 277, 3,5. GANGULY STREET, 3 R FLOOR, ROOM NO.BQS, KOLKATA-700012. SUBSEQUENTLY, IT ALSO BECAME EVIDENT FROM THE DATAB ASE THAT FOLLOWING 3 (THREE) COMPANIES OUT OF THE ABOVE ARE IDENTIFIED PAPER COMPANIES OF KNOWN ACCOMMODATION E NTRY OPERATORS. '(I) PAD'S LESSING AND FINANCE PVT. LTD (ENTRY OPER ATOR-ANKIT BAGRI) (IT) KAYPEE MERCANTILE PVT LTD. (ENTRY OPERATOR- DE EPAK PATV/ARI) TIM INTELLECTUAL SECURITIES PVT, LTD. (ENTRY OPERAT OR- RAJESH AGAR.VAL) STATEMENTS OF ALL THE ABOVE ENTRY OPERATORS HAVE BEEN RECORDED EARLIER IN WHICH THEY HAVE ACCEPTED THAT THEY ARE IN. THE BUSINESS OF PROVIDING DIFFERE NT FORMS OF ACCOMMODATION ENTRIES ON COMMISSION TO VARIOUS BENEFICIARIES USING THE NETWORK OF NUMEROUS BOGUS/P APER COMPANIES. STATEMENTS OF THE SAID ACCOMMODATION ENT RY OPERATORS ARE BEING ENCLOSED FOR YOUR KIND PERUSAL AND NECESSARY ACTION. ON VISITING THE ADDRESS AX 277, 3.3. GANGULY STREET , 3 RD FLOOR, ROOM NA.BGS, KOLKATA- 12 A SIGNBOARD REFLECT ING THE NAMES OF INTELLECTUAL SECURITIES PVT. LTD., PABLA L EASING AND F INANCE LTD.. GIRL FINANCIAL SERVICE PVT. LTD, PADMA ESTAT E PVT. LTD. AND CINDY GOODS &. SUPPLY PVT LTD WAS NOTICED AT TH E ENTRANCE OF THE SINGLE ROOM OFFICE, IT WAS FOUND THAT FEW CO MPUTERS WERE PLACED IN THE ROOM INDICATING THAT SOME ACCOUNTS WERE BEING MAINTAINED THERE HOWEVER, NO BUSINESS ACTIVIT Y-WERE, VISIBLE AS TO BE CARRIED OUT AT THAT PLACE TO THE D EPARTMENTAL INSPECTORS SUNIL KUMAR GAYEN, AND JAYANTA SARKA WHO VISITED THERE. IT WAS HOWEVER REPORTED BY THE EMPLOYEE OF T HAT OFFICE MR VIVEK SHARMA THAT ALL THE SAID 5 COMPANIE S ARE HAVING THEIR REGISTERED OFFICE AT THAT, ADDRESS. THEREAFTER, SUMMONS IN THE CASE OF THE SAID COMPANIES WERE SERV ED AT THAT ADDRESS. HOWEVER, NONE OF THE DIRECTORS OR KE Y PERSONS OF THE COMPANY APPEARED BEFORE THE UNDERSIGNED TILL DATE IN RESPONSE. SUBMISSIONS WERE RECEIVED FROM ALL THE ABOVE ENTITI ES EXCEPT KAYPEE MERCANTILES PVT I ID WHIT H WAS NOT F OUND TO BE EXISTING AT THE GIVEN ADDRESS, WHICH ARE BEING ENCL OSED FOR YOUR KIND PERUSAL AND NECESSARY ACTION. OBSERVATIONS MADE DURING THE COURSE OF INVESTIGATIO N DEARLY INDICATE THAT ALL THESE COMPANIES HAVE BEEN USED BY DIFFERENT ACCOMMODATION ENTRY OPERATOR, TO FACILITA TE ACCOMMODATION ENTRIES IN DIFFERENT FORMS TO VARIOUS BENEFICIARY GROUPS STATEMENTS OF DIRECTORS/KEY PERS ONS COULD NOT BE RECORDED DUE TO THEIR NON-APPEARANCE. INSPECTOR REPORT IS BEING ENCLOSED FOR YOUR KIND PERUSAL. 8 8. TAKING A LEAF OUT OF THIS REPORT, ENQUIRIES WERE MADE IN THE CASE OF THE ASSESSEE AND THE ASSESSEE WAS ASKED TO FURNI SH ITS COMMENTS ON THE ENQUIRY REPORT OF THE INVESTIGATION UNIT, KOLKA TA. THE ASSESSEE WAS FURTHER ASKED TO PRODUCE DIRECTORS/PRINCIPAL OFFICE R OF THE COMPANY FOR EXAMINATION ON OATH. THE ASSESSEE FILED NECESSA RY DETAILS AND REITERATED THAT DETAILS HAVE ALREADY BEEN FILED AND THE TRANSACTIONS WITH IITL NIMBUS GROUP OF COMPANIES ARE BONAFIDE AN D GENUINE. 9. THE ASSESSING OFFICER RUBBISHED THE SUBMISSIONS OF THE ASSESSEE AND CAME TO THE CONCLUSION THAT IN CASE OF CREDIT I N THE NAME OF THIRD PARTIES, IT IS THE DUTY OF THE ASSESSEE TO PROVE TH E IDENTITY OF THE CREDITORS, CAPACITY OF THE CREDITORS TO ADVANCE MON EY AND GENUINENESS OF THE TRANSACTION. THE ASSESSING OFFICER WAS OF TH E FIRM BELIEF THAT THE ASSESSEE HAS FAILED TO PROVE THE CAPACITY OF THE CR EDITOR NAMELY, PABLA LEASING AND FINANCE PVT. LTD. SINCE, ACCORDING TO T HE ASSESSING OFFICER THE ASSESSEE FAILED TO PROVE THE CREDIT WORTHINESS, ADDITIONS HAVE BEEN MADE U/S 68 OF THE ACT AMOUNTING TO RS. 3 CRORES IN EACH A.Y UNDER APPEAL. 9 10. WE FIND THAT THE TRIBUNAL IN THE CASE OF NIMBUS INDIA LTD ITA NOS. 929 AND 930/DEL/2019 FOR A.YS 2013-14 AND 2014-15,V IDE ORDER DATED 10.02.2020, HAS ACCEPTED ALL THE THREE CRUCIAL FACT ORS IN THE CASE OF PABLA LEASING AND FINANCE PVT. LTD, NAMELY, THE IDE NTITY, GENUINENESS OF THE TRANSACTION AND CREDIT WORTHINESS. WE FIND T HAT IN THE CASE OF NIMBUS INDIA LIMITED, QUARREL WAS IN RESPECT OF ADD ITION OF 15 CRORES BEING INVESTMENT DONE BY PABLA LEASING AND FINANCE PVT. LTD TOWARDS THE PURCHASE OF SHARES AT A PREMIUM. AFTER DISCUSSI NG VARIOUS JUDICIAL DISCUSSIONS IN LIGHT OF THE FACT OF INVESTMENT MADE BY PABLA LEASING AND FINANCE PVT. LTD, THE TRIBUNAL CAME TO THE CONC LUSION AS UNDER: 34. THE VARIOUS OTHER DECISIONS RELIED ON BY THE L D. COUNSEL FOR THE ASSESSEE ALSO SUPPORTS HIS CASE THAT NO ADD ITION CAN BE MADE U/S 68 OF THE IT ACT AND IN THE INSTANT CAS E, WHEN THE ASSESSEE HAS SUBSTANTIATED THE THREE INGREDIENT S OF SECTION 68 OF THE IT ACT AND MOREOVER, SUCH AMOUNT HAS BEEN REFUNDED TO THE INVESTOR COMPANIES IN SUBSEQUENT YE ARS WHICH IS MUCH PRIOR TO THE DATE OF SEARCH. 35. SO FAR AS THE DECISION RELIED ON BY THE LD. DR IN THE CASE OF NRA IRON & STEEL (P) LTD. (SUPRA) IS CONCERNED, THE SAME, IN OUR OPINION, IS NOT APPLICABLE TO THE FACTS OF T HE PRESENT 10 CASE SINCE, IN THAT CASE, THE INVESTOR DID NOT APPE AR IN RESPONSE TO THE SUMMONS, THE AO GOT FIELD ENQUIRIES CONDUCTED IN RESPECT OF INVESTOR COMPANIES AND NOTI CES WERE NOT SERVED ON SUCH INVESTOR COMPANIES. NONE OF THE INVESTORS PRODUCED THE BANK STATEMENTS TO ESTABLISH THE SOURC E OF FUNDS IN MAKING SUCH HUGE INVESTMENTS AND INVESTORS WERE SHOWING MEAGER INCOME IN THE RETURN. HOWEVER, IN TH E INSTANT CASE, THE DIRECTORS/MDS OF THE INVESTOR COMPANIES A PPEARED BEFORE THE AO IN RESPONSE TO NOTICE U/S 133(6) AND THEIR STATEMENTS U/S 131 WERE RECORDED AND THEY HAVE CONF IRMED TO HAVE INVESTED IN THE SHARES OF THE ASSESSEE COMPANY . THE INVESTOR COMPANIES HAVE PRODUCED THEIR BANK STATEME NTS AND WERE SHOWING SUBSTANTIAL INCOME AND, MOREOVER, THE AO, IN THE PRECEDING OR SUCCEEDING YEAR IN THE CASE OF THE INVESTOR COMPANIES HAVE ACCEPTED THE INVESTMENT MADE BY THEM IN THE SHARES OF THE ASSESSEE COMPANY IN THE ORDERS PASSED U/S 153A/143(3). THEREFORE, THE DECISION IN THE CASE OF NRA IRON & STEEL (P) LTD. (SUPRA), IN OUR OPINION, IS NOT AP PLICABLE TO THE FACTS OF THE PRESENT CASE. 36. SO FAR AS THE DECISION IN THE CASE OF NDR PROMO TERS PVT. LTD. (SUPRA) IS CONCERNED, THE SAME ALSO IS NOT APP LICABLE IN THE FACTS OF THE PRESENT CASE ESPECIALLY WHEN THE D IRECTORS OF THE INVESTOR COMPANIES APPEARED BEFORE THE AO WH OSE STATEMENTS WERE RECORDED U/S 131 OF THE ACT AND WHO HAVE CONFIRMED TO HAVE INVESTED IN THE ASSESSEE COMPANY, ALL THE 11 INVESTOR COMPANIES ARE ASSESSED TO TAX, THEIR ORDER S HAVE BEEN PASSED U/S 143(3) IN MOST OF THE YEARS, THE AO OF THE INVESTOR COMPANIES ARE AWARE OF THE HUGE INVESTMENT MADE BY THEM IN VARIOUS COMPANIES SINCE WHILE COMPUTING THE DISALLOWANCE U/S 14A R.W. RULE 8D, THE AO HAS COUNT ERED THE HUGE OPENING AND CLOSING INVESTMENT MADE BY THEM TO WARDS SHARE CAPITAL FOR COMPUTING THE AVERAGE INVESTMENT FOR THE PURPOSE OF CALCULATION OF DISALLOWANCE U/S 14A R.W. RULE 8D. THEREFORE, THE DECISION IN THE CASE OF NDR PROMOTER S PVT. LTD. (SUPRA) IS ALSO NOT APPLICABLE TO THE FACTS OF THE INSTANT CASE. THE VARIOUS OTHER DECISIONS RELIED ON BY THE LD. DR ARE ALSO NOT APPLICABLE TO THE FACTS OF THE PRESENT CAS E AND ARE DISTINGUISHABLE. IN THIS VIEW OF THE MATTER, WE ARE OF THE CONSIDERED OPINION THAT THE ADDITION MADE BY THE AO AND SUSTAINED BY THE CIT(A) IS NOT JUSTIFIED. ACCORDING LY, WE DIRECT THE AO TO DELETE THE ADDITION MADE BY HIM U/ S 68 OF THE ACT FOR BOTH THE YEARS. 11. AS MENTIONED ELSEWHERE, FOR THE IMPUGNED A.YS U NDER APPEAL, TRANSACTIONS WITH PABLA LEASING AND FINANCE PVT. LT D HAVE BEEN QUESTIONED BY THE ASSESSING OFFICER ON THE GROUND T HAT THE ASSESSEE HAS FAILED TO ESTABLISH THE CREDIT WORTHINESS. WE A RE OF THE OPINION THAT SINCE THE CREDIT WORTHINESS OF THIS COMPANY HA S BEEN ACCEPTED IN 12 THE CASE OF FLAGSHIP COMPANY OF THE APPELLANT, WE D O NOT FIND ANY MERIT IN THIS FINDING OF THE LOWER AUTHORITIES. 12. FURTHER, ON PERUSAL OF THE CONFIRMATION OF LEDG ER ACCOUNT OF PABLA LEASING AND FINANCE PVT. LTD., WE FIND THAT T HE LOAN HAS BEEN REPAID ON 19.01.2013, WHICH IS MUCH EARLIER THAN TH E DATE OF SEARCH, WHICH IS 26.08.2015. 13. WE FURTHER FIND THAT THE STATEMENT OF SHRI VIRE NDER TRIPARTI, MANAGING DIRECTOR OF PABLA LEASING AND FINANCE PVT. LTD WAS RECORDED UNDER SECTION 131 OF THE ACT ON 22.12.2017 AND THE SAME IS EXHIBITED AT PAGES 109 TO 111 OF THE PAPER BOOK. 14. QUESTION NO 8 OF THAT STATEMENT IS MOST RELEVAN T HERE WHEREIN THE MANAGING DIRECTOR WAS ASKED TO EXPLAIN WHETHER HIS COMPANY HAS MADE ANY INVESTMENT IN THE FORM OF LOAN/SHARE CAPIT AL ETC WITH ANY OF THE COMPANIES OF NIMBUS INDIA LIMITED GROUP. 13 15. IN HIS REPLY, THE MANAGING DIRECTOR CATEGORICAL LY STATED THAT HIS COMPANY HAS GIVEN LOAN OF RUPEES 300 LAKHS TO M/S C APITAL INFRAPROJECT DURING F.Y 2012-13 AND 300 LAKHS IN F.Y 2013-14. 16. IN HIS REPLY, THE MANAGING DIRECTOR ALSO EXPLAI NED THAT SOURCE OF FUND FOR THIS LOAN WAS SALE OF EXISTING INVESTMENTS . THE MANAGING DIRECTOR ALSO ADMITTED THAT THE LOAN HAS BEEN REFUN DED BACK. 17. WITH THIS CLINCHING EVIDENCE, THERE REMAINS NO DOUBT THAT THE ASSESSEE HAS SUCCESSFULLY DISCHARGED ITS ONUS CAST UPON IT BY THE PROVISIONS OF SECTION 68 OF THE ACT. WE DO NOT FIN D ANY MERIT IN THE ALLEGATION OF THE LOWER AUTHORITIES THAT PABLA LEAS ING AND FINANCE PVT. LTD IS ONLY A PAPER COMPANY PROVIDING ACCOMMODATION ENTRIES TO THE NIMBUS INDIA LTD GROUP OF COMPANIES. 18. IN LIGHT OF THE DECISION OF THE TRIBUNAL IN THE CASE OF FLAGSHIP COMPANY NIMBUS INDIA LIMITED, AND FURTHER DRAWING S UPPORT FROM THE STATEMENT OF THE MANAGING DIRECTOR OF PABLA LEASING AND FINANCE PVT., LTD, WE ARE OF THE CONSIDERED VIEW THAT THE ASSESSE E HAS SUCCESSFULLY 14 DISCHARGED THE ONUS AND, THEREFORE, THE ADDITIONS M ADE U/S 68 OF THE ACT DESERVE TO BE DELETED. 19. IN THE RESULT, BOTH THE APPEALS OF THE ASSESSEE IN ITA NOS. 927 & 928/DEL/2019 ARE ALLOWED. THE ORDER IS PRONOUNCED IN THE OPEN COURT ON 04.09 .2020. SD/- SD/- [KULDIP SINGH] [N.K. BILLAIYA] JUDICIAL MEMBER ACCOUNTANT MEMBER DATED: 04 TH SEPTEMBER, 2020 VL/ COPY FORWARDED TO: 1. APPELLANT 2. RESPONDENT 3. CIT 4. CIT(A) 5. DR ASST. REGISTRAR, ITAT, NEW DELHI 15 DATE OF DICTATION DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 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 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 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