Ulhas Vasantra Bagul,, Pune V. Deputy Commissioner of Income-tax,

ITA 938/PUN/2015

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 5299 (ITAT-PUNE)
• Duration Of Justice: 5 year(s) 3 month(s) 23 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 09-10-2020
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: A
• Assessment Year: 2005-2006
• Appeal Filed On: 16-06-2015
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Assessee Lawyers: IS DIRECTED AGAINS T PASSED
• Keywords: Unexplained investment; Rectification of order; Search and seizure; Question of law; Set aside
• Section: 13

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH A, PUNE VIRTUAL COURT BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER ITA NO. 938/PUN/2015 / ASSESSMENT YEAR : 2005-06 ULHAS VASANTRAO BAGUL, PLOT NO.12, SHIVDARSHAN, PARVATI, PUNE 411009 PAN : AEQPB0962E VS. DCIT, CIRCLE-2(1), PUNE APPELLANT RESPONDENT / ORDER PER R.S.SYAL, VP : THIS APPEAL BY THE ASSESSEE IS DIRECTED AGAINST THE ORDER PASSED BY THE CIT(A)-12, PUNE ON 13-03-2015 IN RELATION TO THE ASSESSMENT YEAR 2005-06. 2. THE ASSESSEE HAS FILED CONCISE GROUNDS, WHICH WILL BE ESPOUSED FOR CONSIDERATION. AN ADDITIONAL GROUND HAS ALSO BEEN FILED, READING AS UNDER : WHETHER ON FACTS AND CIRCUMSTANCES OF THE CASE, AN ADDITIO N ON ACCOUNT OF JEWELLERY BELONGING TO FAMILY MEMBERS WAS JUSTIFIED WHEN THE ENTIRE JEWELLERY WAS EXPLAINED AND SUPPORTED. ASSESSEE BY SMT. DEEPA KHARE REVENUE BY SHRI S.P. WALIMBE DATE OF HEARING 08-10-2020 DATE OF PRONOUNCEMENT 09-10-2020 ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 2 3. INSOFAR AS ADMISSION OF THE ADDITION GROUND IS CONCERN ED, WE FIND THAT THE HONBLE SUPREME COURT IN NATIONAL THERMAL POWER COMPANY LTD. VS. CIT (1998) 229 ITR 383 (SC) HAS OBSERVED THAT THE PURPOSE OF THE ASSESSMENT PROCEEDINGS BEFORE THE TA XING AUTHORITIES IS TO ASSESS CORRECTLY THE TAX LIABILITY OF AN ASSESS EE IN ACCORDANCE WITH LAW. IF, FOR EXAMPLE, AS A RESULT OF A JU DICIAL DECISION GIVEN WHILE THE APPEAL IS PENDING BEFORE THE TRIBUNA L, IT IS FOUND THAT A NON-TAXABLE ITEM IS TAXED OR A PERMISSIBLE DEDUCTIO N IS DENIED, WE DO NOT SEE ANY REASON WHY THE ASSESSEE SHOU LD BE PREVENTED FROM RAISING THAT QUESTION BEFORE THE TRIBUNAL FOR THE FIRST TIME, SO LONG AS THE RELEVANT FACTS ARE ON RECORD IN RESPE CT OF THAT ITEM. ANSWERING THE QUESTION POSED BEFORE IT IN AFFIRMATIVE, THEIR LORDSHIPS HELD THAT ON THE FACTS FOUND BY THE AUTHORITIES BELOW , IF A QUESTION OF LAW ARISES (THOUGH NOT RAISED BEFORE THE AUTHORITIE S) WHICH HAS BEARING ON THE TAX LIABILITY OF THE ASSESSEE, THE TR IBUNAL HAS JURISDICTION TO EXAMINE THE SAME. HAVING GONE THROUGH THE SUBJECT MATTER OF THE ADDITIONAL GROUND TAKEN BY THE ASSESSEE , IT IS DISCERNIBLE THAT THE ADDITIONAL GROUND RAISES A PURE QUESTION OF LAW. WE, THEREFORE, ADMIT THE ADDITIONAL GROUND AND WILL TAKE IT UP F OR ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 3 DISPOSAL ON MERITS ALONG WITH THE SECOND ISSUE RAISED BEFORE THE TRIBUNAL. 4. THE FIRST ISSUE RAISED BY THE ASSESSEE THROUGH CONCISE GROUND NO.2 IS AGAINST THE CONFIRMATION OF ADDITION OF RS.10.00 LAKH IN RESPECT OF CASH FOUND DURING THE COURSE OF SEARCH. 5. SUCCINCTLY, THE FACTS OF THE CASE ARE THAT A SEARCH AND SEIZURE ACTION U/S.132 OF THE INCOME-TAX ACT, 1961 (HEREINAFTER A LSO CALLED THE ACT) WAS CONDUCTED ON 24-11-2004 AGAINST THE ASSES SEE AND HIS FAMILY MEMBERS. DURING THE COURSE OF THE SEARCH, CA SH OF RS.11,60,400/- WAS FOUND AT THE ASSESSEES RESIDENCE. THE ASSESSEES EXPLANATION SUBMITTED ABOUT RS.1,60,400/- WAS ACCEPTED. REGARDING THE REMAINING CASH OF RS.10.00 LAKH , WHICH IS SUBJECT MATTER OF THE INSTANT GROUND, THE ASSESSEE STATED THAT S UCH CASH BELONGED TO ONE OF THE TRUSTS, NAMELY, PUNE NAVRATRI MAHOTSAV SHIVSHAKTI PRATISTHAN (PNM TRUST) OF WHICH HE WAS PRESIDENT. THE ASSESSEE SUBMITTED THAT HE WAS ARRANGING KA SHI YATRA FOR THE POOR SENIOR CITIZENS OF THE LOCALITY. FOR THAT PU RPOSE, THE TRUST COLLECTED CERTAIN AMOUNTS WHICH TOTALLED UPTO RS.10.00 LAKH. IT WAS SUCH AMOUNT THAT WAS KEPT AT HIS RESIDENCE. DU RING THE COURSE OF SEARCH ACTION, SOME PERSONS WERE EXAMINED B Y THE ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 4 AUTHORISED OFFICER TO ASCERTAIN THE CLAIM OF THE ASSESSEE. SUCH PEOPLE ADMITTED THAT THEY PAID BETWEEN RS.500/- TO RS.700/- TO PNM TRUST. DURING THE COURSE OF THE ASSESSMENT PROCEEDIN GS, THE ASSESSEE WAS CALLED UPON TO PRODUCE BOOKS OF ACCOUNT AN D CERTAIN OTHER DOCUMENTS OF THE TRUST FOR VERIFYING THE AVAILABILITY OF CA SH OF RS.10.00 LAKH. THE ASSESSEE COULD ONLY FURNISH PHOTOCOP Y OF REGISTRATION OF CONCERNED TRUST, NAMELY, PUNE NAVRATRI MAHOTSAV SHIVSHAKTI PRATISTHAN TRUST . HE STATED THAT THERE WAS NO REGISTRATION EITHER U/S.12A OR U/S.80G. NO BOOKS OF ACCOUN T OF SUCH TRUST WERE FURNISHED. ON PERUSAL OF THE BANK STATEME NTS RECEIVED FROM BANK U/S.133(6) OF THE ACT, THE ASSESSING OFFICER (AO) OBSERVED THAT THERE WERE VERY FEW TRANSACTIONS THROUG H BANK AND NO MAJOR DONATION WAS ACCEPTED FROM DONORS BY WAY O F CHEQUES. SINCE THE ASSESSEE FAILED TO PRODUCE BOOKS OF ACCOUNT DURING THE COURSE OF ASSESSMENT PROCEEDINGS, THE AO TREA TED SUCH CASH OF RS.10.00 LAKH AS BELONGING TO THE ASSESSEE AND M ADE ADDITION FOR THE SAME. THE ASSESSEE SUBMITTED BEFORE THE LD. CIT(A) THAT CASH OF RS.10.00 LAKH BELONGED TO PNM TRUST. HE FURTHER SUBMITTED THAT THE TRUST REFUSED TO HAND OVER BOOKS TO HIM, WHICH WERE NOT CALLED BY THE INCOME-TAX AUTHORITIES FOR ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 5 VERIFICATION. IT WAS STILL FURTHER SUBMITTED THAT HE TENDERED HIS RESIGNATION TO WORK AS PRESIDENT OF THE SAID TRUST ON 04-12-20 04 AND THE AO OUGHT TO HAVE ISSUED NOTICE U/S.131 OR 133 TO THE TRUST FOR VERIFYING THE VERACITY OF HIS CLAIM. UNMOVED, THE LD. CIT(A) AFFIRMED THE VIEW POINT OF THE AO ON THIS COUNT. AGGRIEVED THEREBY, THE ASSESSEE HAS COME UP IN APPEAL BEFORE THE T RIBUNAL. 6. WE HAVE HEARD THE RIVAL SUBMISSIONS THROUGH VIRTUAL COURT AND GONE THROUGH THE RELEVANT MATERIAL ON RECORD. IN THE S EARCH AND SEIZURE ACTION AT THE RESIDENTIAL PREMISES OF THE ASSESSEE , CASH OF RS.11,60,400/- WAS FOUND. THE AO DID NOT DISPUTE THE AVAILABILITY OF CASH TO THE EXTENT OF RS.1,60,400/-. AS REGA RDS THE AVAILABILITY OF CASH OF RS.10.00 LAKH, THE ASSESSEE SUBMITTED THAT SUCH CASH BELONGED TO PNM TRUST OF WHICH HE WAS PRESIDENT. WHEN CALLED UPON TO PRODUCE BOOKS OF ACCOUNT OF THE TRUST, THE ASSESSEE FAILED TO DO SO AND FURTHER SUBMITTED BEFORE THE LD. CIT(A) THAT HE HAD TENDERED HIS RESIGNATION AS PRESIDENT OF THE TRUS T AND THE TRUST HAD REFUSED TO HAND OVER THE BOOKS TO HIM. 7. SECTION 132(4A) PROVIDES THAT : ` WHERE ANY .. MONEY . IS FOUND IN THE POSSESSION OR CONTROL OF ANY PERSON IN THE COU RSE OF A SEARCH, IT MAY BE PRESUMED (I) THAT SUCH . MONEY. BELONGS ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 6 TO SUCH PERSON;. THIS PROVISION LAYS DOWN THAT FINDING OF CASH ETC. DURING THE COURSE OF SEARCH PROCEEDS WITH THE PREMIS E THAT IT BELONGS TO THE PERSON SEARCHED. IN THAT VIEW OF THE MATTE R, IT IS FOR THE PERSON SEARCHED TO SUBMIT EXPLANATION ABOUT THE SOURCE OF THE CASH TO THE SATISFACTION OF THE AO SO AS TO AVOID ITS INCLUSION IN THE TOTAL INCOME. THE REBUTTABLE PRESUMPTION AGAINST THE PERSON SEARCHED NEEDS TO BE CLEARED BY SUCH PERSON. THUS THE ONUS PROBANDI TO EXPLAIN THE SOURCE OF THE AVAILABILITY OF CASH IS ON THE PERSON SEARCHED AND NOT THE OTHER WAY AROUND. AS SUCH A PRESUMPTION IS AGAINST THE PERSON SEARCHED, HE CANNOT CAST A REVERSE OBLIGATION ON THE REVENUE AUTHORITIES TO PROVE THAT THE MONEY FOUND BELONGS TO HIM BEFORE MAKING ANY ADDITION. I F THE PERSON SEARCHED FAILS TO DISCHARGE SUCH BURDEN, ADDITION HAS TO FOLLOW. 8. ADVERTING TO THE FACTS OF THE INSTANT CASE, IT IS FOUND THAT CASH OF RS.10.00 LAKH WAS FOUND FROM THE RESIDENTIAL PREMISES OF THE ASSESSEE. APART FROM MAKING SUBMISSION THAT SUCH CASH BELONGED TO TRUST AND WAS KEPT WITH HIM FOR SAFE CUSTODY, THE ASSES SEE COULD NOT EVEN PROVE THE AVAILABILITY OF CASH WITH THE TRUST, WHICH WAS A PRIMARY THING TO BE FOLLOWED BY FURTHER PROVING THAT SUCH C ASH WAS ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 7 KEPT WITH HIM FOR SAFE KEEPING. THE ASSESSEE TRIED TO FIN D AN ESCAPE ROUTE BY SUBMITTING RESIGNATION TO THE TRUST OF WHICH H E WAS PRESIDENT AND FURTHER PLACED BEFORE THE AO A COPY OF LETTER OF THE TRUST REFUSING TO HAND OVER BOOKS FOR THE PURPOSES OF PE RUSAL BY THE INCOME-TAX AUTHORITIES. THE CONTENTION OF THE LD. AR THAT THE FACTUM OF THE EXISTENCE OF TRUST WAS ESTABLISHED AND HENCE TH E CONTENTION SHOULD HAVE BEEN ACCEPTED, IS WITHOUT MERIT. THE F ACT THAT THE TRUST WAS EXISTING OR THE TRUST GAVE SOME EXPLANATION IS IRRELEVANT INSOFAR AS THE AVAILABILITY OF CASH OF RS.10.00 LAKH WITH THE ASSESSEE IS CONCERNED. THE ONLY RELEVANT CRITERIA TO CO ME OUT OF THE RIGOUR OF SECTION 132(4A) WAS TO ESTABLISH TO THE SATISFACTIO N OF THE AO THAT CASH OF RS.10.00 LAKH FOUND FROM THE RESIDEN CE OF THE ASSESSEE BELONGED TO THE TRUST. SINCE THE PRIMARY FACTOR OF THE AVAILABILITY OF CASH OF RS.10.00 LAKH REMAINED UNPROVED WITH THE HELP OF BOOKS OF ACCOUNT OF THE TRUST, THE OTHER ARGUMENTS ABOUT THE EXISTENCE OF TRUST OR TENDERING RESIGNATION ETC., PALE INTO INSIGNIFICANCE. WE, THEREFORE, UPHOLD THE IMPUGNED ORDER ON THIS SCORE AND CONFIRM AND ADDITION OF RS.10.00 LAKH. ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 8 9. THE ONLY OTHER ISSUE RAISED THROUGH TWO CONCISE GROUNDS AND ONE ADDITIONAL GROUND PERTAINS TO CONFIRMATION OF THE ADDITION O N ACCOUNT OF JEWELLERY. 10. THE FACTS ANENT TO THE ABOVE ISSUE ARE THAT DURING THE C OURSE OF SEARCH ACTION, JEWELLERY WORTH RS.20,53,987/- WAS FOU ND FROM THE RESIDENCE OF THE ASSESSEE AS PER PANCHANAMA DATED 0 3-12-2004. FURTHER, FROM BANK LOCKERS OF THE ASSESSEE, CERTAIN JEWE LLERY WAS ALSO FOUND, WHICH WAS CLAIMED TO BE BELONGING TO GODDESS LAXMIMATA . IN THE ABSENCE OF THE ASSESSEE COMING OUT WITH A SATISFACTORY EXPLANATION ABOUT THE SOURCE OF SUCH JEWELLERY, TH E AO MADE AN ADDITION OF RS.20,53,987/-. THEREAFTER, AN ORD ER U/S.154 OF THE ACT WAS PASSED ON 01-03-2007 MAKING A FURTHER AD DITION OF RS.13,27,778/- ON ACCOUNT OF JEWELLERY FOUND IN THE BANK LOCKERS DURING THE COURSE OF SEARCH ACTION, WHICH REMAINED TO BE CONSIDERED WHILE COMPUTING THE TOTAL INCOME IN THE ORIGINAL ASSESSMENT. THE LD. CIT(A) DEALT WITH THE ADDITION OF RS.20,53,987/- BY INCORPORATING THE ASSESSEES SUBMISSIO NS ABOUT THE JEWELLERY WORTH RS.13,27,778/- PERTAINING TO GODDESS LAXMIMATA AND JEWELLERY WORTH RS.20,53,987/- FOUND AT THE RESIDENCE CLAIMED TO BE BELONGING TO FAMILY MEMBERS OF THE ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 9 ASSESSEE. HE OBSERVED THAT IF THE JEWELLERY OF GODDESS LAXMIMATA WAS MIXED UP WITH ASSESSEES FAMILY MEMBERS JEWELLERY, THERE SHOULD HAVE BEEN SOME IDENTIFICATION MARKS AS TO ITS OWNERSHIP , WHICH WAS NOT THE CASE. HE CAME TO HOLD THAT, AT BEST, ADDITION ON ACCOUNT OF UNEXPLAINED INVESTMENT IN JEWELLERY COULD BE MAD E IF SOME INVESTMENT WAS MADE DURING THE YEAR UNDER CONSIDERA TION. THAT IS HOW, HE REMITTED THE MATTER TO THE AO FOR VERIFYING IF THE BANK LOCKERS WERE OPERATED DURING THE YEAR AND THEN DEC IDE THE ISSUE ACCORDINGLY. AGGRIEVED THEREBY, THE ASSESSEE HAS C OME UP IN APPEAL BEFORE THE TRIBUNAL. 11. WE HAVE HEARD THE RIVAL SUBMISSIONS AND COGITATED OVER THE RELEVANT MATERIAL ON RECORD. IT IS SEEN THAT THE LD. CIT(A) HA S RESTORED THE MATTER TO THE AO GIVING CERTAIN DIRECTIONS. SECTION 251(1), AFTER AMENDMENT BY THE FINANCE ACT, 2001, DOES NO T EMPOWER CIT(A) TO RESTORE THE MATTER TO THE AO FOR VERIFICA TION AND A FRESH DECISION. HE CAN CALL FOR A REMAND REPORT F ROM THE AO, BUT THE DECISION HAS TO BE TAKEN BY HIM THIS WAY OR THAT WAY . AS THE LD. CIT(A) HAS RESTORED THE MATTER TO THE AO WITHOUT TAKIN G ANY POSITIVE DECISION, THE IMPUGNED ORDER GETS VITIATED. ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 10 12. IT IS OBSERVED THAT TWO TYPES OF JEWELLERIES WERE FOU ND DURING THE COURSE OF SEARCH. JEWELLERY WORTH RS.20,53,987/- WAS FOUND AT THE RESIDENTIAL PREMISES OF THE ASSESSEE AND JEWELLERY WORTH RS.13,27,778/- WAS FOUND FROM THE TWO BANK LOCKERS. THE AO, IN THE ASSESSMENT ORDER PASSED U/S.143(3), MIXED UP THE ASS ESSEES EXPLANATION ABOUT THE JEWELLERY LYING IN BANK LOCKERS PERTAINING TO GODDESS LAXMIMATA AND THE JEWELLERY FOUND AT THE RESIDENTIAL PREMISES OF THE ASSESSEE. IN THE RECTIFICATION ORDER, THE A O SIMPLY MADE SEPARATE ADDITION OF RS.13,27,778/- TOWARDS JEWELLERY FOUND IN BANK LOCKERS FOR WHICH EXPLANATION OF THE ASSESSEE WAS THAT THE SAME PERTAINED TO GODDESS LAXMIMATA. WHEN THE MATTER CAME UP BEFORE THE LD. CIT(A), HE DEALT WITH ONLY THE ADDITION OF RS.20,53,987/- BY PRESUMING AS IF IT PERTAINED ONLY TO THE JEWELLERY FOUND IN THE BANK LOCKERS. WE HAVE GONE THROU GH THE PANCHANAMA DATED 24-01-2005 MARKED AS ANNEXURE C CON TAINING DETAILS OF JEWELLERY FOUND IN BANK OF MAHARASHTRA LOCKER NO .125 AND FOUND IN BANK OF MAHARASHTRA LOCKER NO.209. TOTAL VALUE OF JEWELLERY IN THESE TWO LOCKERS, AS PER THE PANCHNAMA, COMES TO RS.13,27,778/-. AS AGAINST THAT, JEWELLERY FOUND AT THE RE SIDENCE OF THE ASSESSEE WAS RECORDED THROUGH PANCHANAMA DATED 03- 12-2004, ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 11 A COPY OF WHICH HAS ALSO BEEN PLACED AT PAGES 7 ONWARD S OF THE PAPER BOOK. PAGE 15 CONTAINS SUMMARY OF SUCH JEWELLERY F OUND AT THE RESIDENCE OF THE ASSESSEE, WHICH COMES TO RS.20,53,9 87/-. IT IS THUS SEEN THAT THE AUTHORITIES BELOW MIXED UP THE JEWELLERY FOU ND FROM TWO SEPARATE LOCKERS AND THAT AT THE RESIDENTIAL PREMISE S OF THE ASSESSEE AND PROCEEDED TO DECIDE THE ISSUE WITHOUT CLARIFYING THEMSELVES ABOUT THE TRUE FACTUAL SCENARIO OF THE ISSUE. A S AGAINST THAT, THE LD. AR ARGUED THAT JEWELLERY FOUND FROM LOCKER NO. 125 OF BANK OF MAHARASHTRA PERTAINS TO GODDESS LAXMIMATA. AS REGARDS THE JEWELLERY FOUND FROM LOCKER NO.209 OF BANK OF MAHAR ASHTRA AND THAT FOUND PHYSICALLY AT THE RESIDENCE OF THE ASSESSEE, SHE SUBMITTED THAT THE SAME PERTAINED TO FAMILY MEMBERS OF THE ASSESSEE, FOR WHICH NO BENEFIT OF INSTRUCTION NO.1916 D ATED 11-05- 1994 WAS ALLOWED. SINCE THE ISSUE HAS NOT BEEN EXAMINED B Y THE AUTHORITIES BELOW IN CORRECT PERSPECTIVE AND FURTHER THE STATU S OF ASSESSMENT OF JEWELLERY IN THE HANDS OF OTHER FAMILY MEMBER S, IF ANY, IS NOT CLEAR, WE ARE OF THE CONSIDERED OPINION THAT IT W ILL BE IN THE FITNESS OF THINGS IF THE IMPUGNED ORDER ON THIS SCORE IS SET ASIDE AND THE MATTER IS REMITTED TO THE AO FOR A DE NOVO ADJUDICATION OF ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 12 THIS ISSUE AS PER LAW AFTER ALLOWING REASONABLE OPPORTUNITY OF HEARING TO THE ASSESSEE. WE ORDER ACCORDINGLY. 13. IN THE RESULT, THE APPEAL IS PARTLY ALLOWED FOR STATISTICAL PURPOSES. ORDER PRONOUNCED IN THE OPEN COURT ON 09 TH OCTOBER, 2020. SD/- SD/- (PARTHA SARATHI CHAUDHURY) (R.S.SYAL) JUDICIAL MEMBER VIC E PRESIDENT PUNE; DATED : 09 TH OCTOBER, 2020 / COPY OF THE ORDER IS FORWARDED TO : 1. / THE APPELLANT; 2. / THE RESPONDENT; 3. THE CIT(A)-12, PUNE 4. 5. THE CIT CENTRAL, PUNE , , / DR A, ITAT, PUNE 6. / GUARD FILE / BY ORDER, // TRUE COPY // SENIOR PRIVATE SECRETARY , / ITAT, PUNE ITA NO.938/PUN/2015 ULHAS VASANTRAO BAGUL 13 DATE 1. DRAFT DICTATED ON 08-10-2020 SR.PS 2. DRAFT PLACED BEFORE AUTHOR 09-10-2020 SR.PS 3. DRAFT PROPOSED & PLACED BEFORE THE SECOND MEMBER JM 4. DRAFT DISCUSSED/APPROVED BY SECOND MEMBER. JM 5. APPROVED DRAFT COMES TO THE SR.PS/PS SR.PS 6. KEPT FOR PRONOUNCEMENT ON SR.PS 7. DATE OF UPLOADING ORDER SR.PS 8. FILE SENT TO THE BENCH CLERK SR.PS 9. DATE ON WHICH FILE GOES TO THE HEAD CLERK 10. DATE ON WHICH FILE GOES TO THE A.R. 11. DATE OF DISPATCH OF ORDER. *