The DY CIT Central -1 Bhopal, Bhopal V. M/s Vardhman Infra Estate P Ltd, Bhupal

ITSSA 30/Ind/2019

• Counselvise Citation: [2022] 104 COUNSELVISE.COM (IT) 3140 (ITAT-INDORE)
• Duration Of Justice: 3 year(s) 5 month(s) 16 day(s)
• Appeal Type: Income Tax (Search & Seizure) Appeal
• Pronouncement Date: 22-08-2022
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: DB
• Next Hearing Date: 19-07-2022
• Assessment Year: 2016-2017
• Appeal Filed On: 07-03-2019
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Keywords: Document seized; Additional evidence; Documents seized
• Section: 132; 143(3); 133A; 113; 13

Judgement Text

IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER (Conducted through Virtual Court) IT(SS)A No. 30/Ind/2019 (Assessment Year: 2016-17) JCIT (OSD)(Central)-I Bhopal Vs. Vardhman Infra Estate Private Limited, Ambrosia Country Apartment, Maveshi Bazar, Kalagun Sagar Road, Near Bypass, NH-26, Lalitpur (Appellant / Revenue) (Respondent / Assessee) PAN: AADCV5876F Assessee by Ms. Nisha Lahoti, AR Revenue by Shri P.K. Mitra, CIT-DR Date of Hearing 20.07.2022 Date of Pronouncement 23.08.2022 O R D E R Per B.M. Biyani, A.M.: 1. This appeal by Revenue is directed against the order dated 14.12.2018 of learned Commissioner of Income-Tax (Appeals)-3, Bhopal [“Ld. CIT(A)”] in Appeal No. CIT(A)-3/BPL/IT-11621,11623,11652,11657,11662/2017-18, arising out of the order of assessment dated 22.12.2017 passed by the learned DCIT, Central-1, Bhopal [“Ld. AO”] u/s 143(3) of the Income-tax Act, 1961 [“the Act”], concerning the Assessment-Year 2016-17. 2. The assessee is a company engaged in real estate development. A search u/s 132 was conducted on 07.01.2016 to 08.01.2016 on one M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 2 of 13 Shivhare Group wherein certain material belonging to the assessee were seized. Further a survey u/s 133A was also conducted on the assessee on 07.01.2016 wherein certain material was found. For the relevant assessment-year 2016-17 under consideration (search-year / survey-year), the assessee submitted return declaring a total income of Rs. 57,37,490/-. The Ld. AO completed assessment vide order dated 22.12.2017 u/s 143(3) at a total income of Rs. 7,42,02,138/- after making certain additions. Being aggrieved, the assessee filed appeal to Ld. CIT(A). During appellate proceeding, the Ld. CIT(A) allowed part-relief to the assessee. Now being aggrieved by the order of Ld. CIT(A), the revenue has filed this appeal before us. 3. The Grounds of appeal are as under: “1. On the facts and in the circumstances of the case, the Ld. CIT(A) erred in not remanding the issues back to the AO while adjudication the matter as no factual response to the detailed show cause was furnished by the appellant before the AO. 2. On the fact and in the Circumstances of the case the Ld. CIT(A) has erred in deleting the addition of Rs. 32,00,000/- and Rs. 99,78,000/- made by AO on account of unexplained cash payments for A. Y. 2016-17. 3. On the fact and in the Circumstances of the case the Ld. CIT(A) has erred in deleting the addition of Rs. 5,52,86,648/- made by AO on account of unexplained cash receipts for A.Y. 2016-17.” Ground No. 1: 4. In Ground No. 1, the revenue has claimed that the Ld. CIT(A) has erred in not remanding the issues back to the AO while adjudicating the matter as no factual response to the detailed show-cause was furnished by the assessee to Ld. AO. The Ld. AR pointed out that the Ld. CIT(A) has categorically mentioned in Para No. 1.1 / Page No. 6 of the order that the Ld. AO was asked to specify whether he / she would like to be present at the time of hearing in view of provision of section 250(2)(b) of the Act but in absence of any request from the Ld. AO, he had presumed that the AO does M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 3 of 13 not want to attend the hearings personally. Ld. AR further submitted that the assessee has not submitted any new or additional evidence to the Ld. CIT(A). The evidences as seized during search were available before Ld. AO and the same were only required to be examined, analysed and considered by Ld. CIT(A) during appeal. According to Ld. AR, in absence of any new or additional evidence, there was no need to call for remand-report. Therefore, in such circumstances, the Ground taken by the revenue does not have strength. Ld. DR could not controvert these submissions of Ld. AR. Being so, we find merit in the submissions of Ld. AR and are inclined to dismiss Ground No. 1 of Revenue. Ground No. 2: 5. Ground No. 2 relates to the addition of Rs. 32,00,000/- and Rs. 99,78,000/- made by AO on account of unexplained cash payments. 5.1 During assessment-proceeding, Ld. AO found three vouchers dated 28.08.2015, 12.08.2015 and 19.08.2015 by which the assessee had made cash-payments of Rs. 10,00,000/-, Rs. 20,00,000/- and Rs. 2,00,000/- respectively, aggregating to Rs. 32,00,000/-. Copies of these vouchers are embodied in the assessment-order. Further, the Ld. AO observed that the assessee has made cash-payments of three Bills of ATIQ Sons, amounting to Rs. 37,11,000/-, 34,88,000/- and Rs. 27,79,000/-, aggregating to Rs. 99,78,000/-. While completing assessment, the Ld. AO made addition of Rs. 32,00,000/- and Rs. 99,78,000/- on the footing that the assessee has failed to explain these documents. 5.2 During appellate proceeding, the Ld. CIT(A) deleted additions by observing as under: “4.3 Ground No 3 for A.Y. 2012-13, 2013-14, 2014-15 & 2016- 17; Ground No 2 for A.Ys. 2016-17:- Through these grounds of appeal, the appellant has challenged the addition of Rs. 4,39,584/- in A.Y. 2012-13, Rs. 14,00,000/- in A.Y. 2013-14, Rs.1,99,815/- in A.Y. 2014-15, Rs. 99,78,000/- in A.Y. M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 4 of 13 2016-17, and Rs. 32,00,000./- in A.Y. 2016-17 on account of unexplained cash payments. The search and seizure operation has been carried out at the office and business premises of the Gupta Jai & Company, Chartered Accountants, Mayur Apartment, Near Kunj Bihari Mandir, Jhansi. Cash books Marked as A-1, A-2, A-8 were found and impounded. The appellant company is executing the housing project at Lalitpur at that time. The accounting clerk recorded day-to-day transaction in the cash book. The accounting clerk used to prepare two copies. The transaction in these cash books are receipts and payment in respect of the project. The unexplained payment of Rs. 4,39,584/- in A.Y. 2012-13, Rs. 14,00,000/- in A.Y. 2013- 14, Rs.1,99,815/- in A.Y. 2014-15, Rs. 32,00,000/- in A.Y. 2016-17 and Rs. 99,78,000/- in A.Y. 2016-17 has been recorded in the cash books. The A.O. considered the receipt and made the addition accordingly. The A.O. is not justified on making the addition on account of payment made, because this payment is made out of the cash available in the cash book maintained by the appellant. It is nothing but the double addition of the same amount. The A.O. cannot make addition of receipts and expenditure separately. On this issue reliance is placed on the decision in case of Shyam Biri Works Ltd (2013) 38 taxmann 228 (Allahabad) and Suresh Chand Talera (2005) 152 Taxmann 348 (M.P.). In case of Jogender Singh & Co. Etah, ITAT Agra Bench, Agar in ITA No. 213/Agral2012 in order dated 26-07-2013 held in similar situation that CIT(A) was correct in applying suitable NP rate instead of disallowances of 50% of expenses. In case of M/s Choudhary and Brothers, Jaipur, ITAT Bench A, Jaipur in ITA no. 879/JP/2011 vide order dated 25-05-2012 held that the AO was not justified in making separate additions on different heads, under deemed rejection of books of a/c u/s 145(3). It is rather felt that he should have made a composite/common addition towards the lower net profit shown by the appellant. The Hon'ble ITAT, Indore while deciding the case of S.K. Jain v Dy. CIT(2016) 27 ITJ 113 (Trib.-Indore) in ITA Nos.211Ind/2013 and 604/Indl2012 and appeal no. (2016) 28 ITJ 123(Trib.Indore) estimated the net profit @ 6.25% in the civil construction business. The hon'ble ITAT, Indore while deciding the ITA No.265/Ind/2014, dated 30-09-2015 for the A.Y. 2010-11 in the case of Shri Rajendra Khandelwal adopted 8% net profit on the total contract receipt. Since the net profit rate @ 8.46% has already been adopted, the addition made by the AO amounting to Rs. 4,39,584/- in A.Y. 2012-13, Rs. 14,00,000/- in A.Y. 2013- 14, Rs.1,99,815/- in A.Y. 2014-15, Rs. 99,78,000/- in A.Y. 2016- 17, and Rs. 32,00,000/- in A.Y. 2016-17 is Deleted. Therefore, the appeal on these grounds is allowed.” M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 5 of 13 5.3 Before us, Ld. DR relied upon the order of Ld. AO and claimed that the Ld. AO has made additions on the basis of seized documents which were not explained by the assessee during assessment-proceeding. Therefore the additions made by Ld. AO are in order, which must be upheld. 5.4 Per contra, Ld. AR submitted that the assessee has given sufficient explanation of the documents to Ld. AO in Para No. 2(i) and 3(i) of the reply filed in response to the show-cause notices dated 06.12.2017 and 11.12.2017 issued by Ld. AO, a copy of the reply being placed at Page No. 35 and 36 of the Paper-Book. Therefore, the observation of Ld. AO that no explanation was given is factually incorrect. Ld. AR further submitted that the assessee has also filed explanation of the documents to Ld. CIT(A) on Page No. 9 of the letter dated 20.11.2018, which is placed at Page No. 16 to 17 of the Paper-Book. Drawing attention to these papers available in the Paper-Book, Ld. AR submitted that the cash-payments of Rs. 10,00,000/-, Rs. 20,00,000/- and Rs. 2,00,000/- forming part of the addition of Rs. 32,00,000/- were in the nature of refund of booking-amounts to the customers. Regarding the alleged cash-payments of Rs. 99,78,000/-, the assessee submitted an explanation that there were three Running-Bills of M/s ATIQ Sons, amounting to Rs. 37,11,000/-, 34,88,000/- and Rs. 27,79,000/-. M/s ATIQ Sons is a contractor who has done contract-work for the assessee and submitted Running-Bills. The payments of these Running- Bills, made by assessee from time to time, were duly recorded in the regular books of account maintained by the assessee. Referring to Para No. 4.3 of the order of Ld. CIT(A), reproduced earlier, the Ld. AR pointed out that the Ld. CIT(A) has also observed that these payments are recorded in the books of account of assessee. Therefore, the impugned payments are not out of books of account. Alternatively, Ld. AR argued that even assuming but not accepting that these cash-payments were not recorded in the books of account of assessee, the Ld. CIT(A) was also justified in holding that these unexplained cash-payments were off-set against the unexplained-cash- receipt of business separately added by Ld. AO, which shall also be dealt with in next Ground of this appeal. Since the Ld. AO has made a separate M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 6 of 13 addition of unexplained cash-receipts, addition of unexplained cash- payments has resulted in double addition, which is not justified. Thus, viewed from any angle, the additions of Rs. 32,00,000/- and Rs. 99,78,000/- made by Ld. AO were not sustainable and rightly deleted by Ld. CIT(A). 5.5 We have considered rival submissions of both sides and perused the material held on record. Firstly, we observe that the assessee has given explanation of the alleged cash-payments to Ld. AO which is very much evident from the papers placed in the Paper-Book pointed out by Ld. AR. We observe that the assessee has also given sufficient explanation to Ld. CIT(A) during appellate proceeding. On perusal of explanation, we observe that the assessee has claimed that these cash-payments are recorded in the books of account and the Ld. CIT(A) has also accepted this fact in his order. Secondly, we also find sufficient weightage in the contention raised by Ld. AR, which is also a conclusion taken by Ld. CIT(A), that even if the said payments are treated as not recorded in the books of assessee, the Ld. AO has made a separate addition on account of unexplained cash-receipts. Therefore, the unexplained cash-payments are offset against the unexplained cash-receipts and there should not be any separate addition of undisclosed cash-payments. Thus, both ways, we find merit in the submission of Ld. AR that no addition could have been made by Ld. AO. Being so, we do not find any infirmity in the action of Ld. CIT(A) in deleting the additions. Therefore, we upheld the action of Ld. CIT(A). Accordingly, Ground No. 2 of the revenue is also dismissed. Ground No. 3: 6. Ground No. 3 relates to the addition of Rs. 5,52,86,648/- on account of unexplained cash-receipts. 6.1 The Ld. AO has made this addition by observing as under: “11.2 During the course of survey at UPO-3 certain incriminating documents of the assessee have been impounded. The details of M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 7 of 13 the documents are hereunder: LPS PAGE No. F.Y. Date Description Amount BK-8 6 2012-13 08.11.2012 Cash Book 500000 LP-05 14 2015-16 25.07.2015 Details of Villa No B-17 purchased by Mr. Neeraj Jain 5100000 LP-05 13 2015-16 11.06.2015 Details of Villa No A-7 & 8 purchased by Mr. Subhash 11945667 LP-05 12 2015-16 16.04.2015 Details of Villa No B-03 purchased by Mr. Sanjeev Kadanki 4453032 LP-05 11 2015-16 02.07.2015 Details of Villa No B-7 and 8 purchased by Dr. Rajeev 10409450 LP-05 10 2015-16 05.08.2015 Details of Villa No B-12 purchased by Arun Singhai 5450000 LP-05 9 2015-16 10.07.2015 Details of Villa No B-14 purchased by Mr. Vinod Rai 4624548 LP-05 30 2015-16 Details of amount received against booking of flat owners 13303951 Total 55786648 On-going through the impounded material referred above it is clear that the documents are extremely incriminating and have details of huge amount of cash receipts/payments. The assessee was requested to explain the documents. The sample copy of the documents is as under: M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 8 of 13 The assessee has failed to explain the document. Considering the failure of the assessee to explain the document and considering the incriminating nature of the documents the addition of Rs. 5,00,000/- during AY 2013-14 and Rs. 5,52,86,648/- during AY 2016-17 is hereby made as unexplained cash-receipts.” 6.2 During appellate proceeding, the Ld. CIT(A) deleted this addition by observing as under: “4.4 Ground No 4 for A.Y. 2016-17:- Through this ground of appeal, the appellant has challenged the addition of Rs. 5,52,86,648/- in A.Y. 2016-17 on account of unexplained cash receipts. During survey various incriminating documents were found and impounded. The detail of these documents are as under:- LPS PAGE No. F.Y. Date Description Amount BK-8 6 2012-13 08.11.2012 Cash Book 500000 LP-05 14 2015-16 25.07.2015 Details of Villa 5100000 M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 9 of 13 No B-17 purchased by Mr. Neeraj Jain LP-05 13 2015-16 11.06.2015 Details of Villa No A-7 & 8 purchased by Mr. Subhash 11945667 LP-05 12 2015-16 16.04.2015 Details of Villa No B-03 purchased by Mr. Sanjeev Kadanki 4453032 LP-05 11 2015-16 02.07.2015 Details of Villa No B-7 and 8 purchased by Dr. Rajeev 10409450 LP-05 10 2015-16 05.08.2015 Details of Villa No B-12 purchased by Arun Singhai 5450000 LP-05 9 2015-16 10.07.2015 Details of Villa No B-14 purchased by Mr. Vinod Rai 4624548 LP-05 30 2015-16 Details of amount received against booking of flat owners 13303951 Total 55786648 Further, the AO required assessee to explain these documents, however assessee before AO failed to explain the same. 4.4.1 Appellant during appellate proceedings submitted that the various documents found during survey represents receipt from various customers against sale of villas. These villas were sold by appellant and the brief details are as under:- Date Particulars Sale Value Cheque Cash 25.07.2015 Villa No. B-17 5100000 1200000 2600000 05.08.2015 Villa No. B-12 5450000 2200000 2700000 10.07.2015 Villa No. B-14 4624548 2050000 1000000 11.06.2015 Villa No.A-7 & A-8 11945667 4170000 6200000 16.04.2015 Villa No.B-03 4453032 3202955 810000 02.07.2015 Villa No.B-7 & B-8 10409450 6200000 3500000 Appellant further submitted that sum of Rs. 5,52,86,648/- represents sale receipts. Appellant on sale of villas received Rs. 1,90,22,955/-- through cheque and Rs. 1,68,10,000/- in cash from various customers. The amount received through cheque has been shown in regular books of account and taken into account M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 10 of 13 while filing return of income. However the cash receipt are not properly shown in books of account, but the entire cash receipt cannot be income of the appellant. The appellant has shown the net profit on total receipts as per audited books @ 8.46 % which is very reasonable in case work was executed. The AO is not justified in making the addition equal to the total cash receipts. The Hon'ble ITAT, Indore while deciding the case of S.K. Jain v Dy. CIT(2016) 27 ITJ 113 (Trib.-Indore) in ITA Nos. 21/Ind/2013 and 604/Indl2012 and appeal no. (2016) 28 ITJ 123 (Trib. Indore) estimated the net profit @ 6.25% in the civil construction business. The hon'ble ITAT, Indore while deciding the ITA No.265/Ind/2014, dated 30-09-2015 for the A.Y. 2010-11 in the case of Shri Rajendra Khandelwal adopted 8% net profit on the total contract receipt. It will be appropriate to adopt 8.46% net profit on the total cash receipt as shown by the by the appellant in the A.Y. 2013-14 to 2016-17. Therefore, the net profit earned by the appellant on cash receipt of Rs. 1,68,10,000/- (Rs. 63,00,000/- + Rs.1,05,10,000/-) is equal to Rs. 14,22,126/- (Rs.l,68,10,000/- x 0.0846) in A.Y. 2016-17; The appellant during the survey proceedings declared additional income of Rs. 32,00,000/- on this account and the same has also been offered for taxation while filing return of income for AY 2016-17. Therefore the addition of Rs. 14,22,126/- is set off against the declaration made by the appellant during survey and no addition is made to the income of the appellant on this account. 4.4.2 Thereafter, appellant stated that a sum of Rs. 1,33,03,951/- was outstanding balance which was to be received from various customers. Since the sum of Rs.1,33,03,951/- was never received by the appellant in the year under consideration, the same cannot be added to the income of the appellant. Thus, the AO was not justified in making addition on this account. Therefore, the addition made by the AO on account of unexplained cash receipt as stated above is not called for and is directed to be deleted. Therefore appeal on this ground is allowed.” 6.3 Before us, the Ld. DR relied upon the order of Ld. AO and claimed that the Ld. AO has made addition on the basis of seized documents which were not explained by the assessee during assessment-proceeding. Therefore, the addition made by Ld. AO is fully justified and must be upheld. 6.4 Per contra, Ld. AR submitted that the seized documents are self- explanatory in as much as they contain the complete details. Ld. AR M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 11 of 13 submitted that there was necessity of correct-analysis by Ld. AO and no explanation from assessee was needed. Going further on the analysis of the impugned sum of Rs. 5,52,86,648/-, the Ld. AR submitted that the assessee is engaged in the business of real estate and the transactions involving the sum of Rs. 5,52,86,648/- were in the nature of sale of flats / houses to different buyers, the details of which are incorporated in the order of Ld. CIT(A), reproduced above. Ld. AR submitted that out of the total sum of Rs. 5,52,86,648/-, the assessee had received a sum of Rs. 1,90,22,955/-- through cheques, Rs. 1,68,10,000/- in cash and the remaining amount was due. Ld. AR submitted that the receipt of Rs. 1,90,22,955/- is made through cheques and the same are fully recorded in the books of assessee, hence no addition was required. Similarly, no addition was required for the amount which was due but not received. Thus, the addition was required only and only in respect of the cash-receipts of Rs. 1,68,10,000/-. Ld. AR submitted that even in respect of cash-receipts, full addition of Rs. 1,68,10,000/- was not warranted, only profit-element was required to be added. Ld. AR submitted that the Ld. CIT(A) has correctly observed that the net-profit rate of assessee was 8.46% which if applied on cash-receipt of Rs. 1,68,10,000/- results in a profit of Rs. 14,22,126/-. Thus, the Ld. CIT(A) has arrived at the undisclosed net profit of Rs. 14,22,126/-. Ld. AR further submitted that the assessee had already offered income of Rs. 32,00,000/- on this account while filing return of income which was more than the undisclosed income of Rs. 14,22,126/- computed by Ld. CIT(A) and therefore the Ld. CIT(A) finally concluded that no addition was warranted. Thus, after a careful consideration of the factual matrix, the Ld. CIT(A) deleted the addition of Rs. 5,52,86,648/- made by Ld. AO and there in no fault in the action of Ld. CIT(A). 6.5 We have considered rival submission of both sides and perused the material held on record. On a careful consideration of the relevant material held on record including the papers filed in the Paper-Book, we observe that the impugned sum of Rs. 5,52,86,648/- had three components, viz. (i) cheque-receipts of Rs. 1,90,22,955/-, (ii) cash-receipts of Rs. 1,68,10,000/-, M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 12 of 13 and (iii) remaining amount was due. The Ld. DR has not controverted these facts and figures. Then we find sufficient force in the submission of Ld. AR that it is only (ii) component i.e. the cash-receipts of Rs. 1,68,10,000/- which requires addition and other two components do not require any addition. Going further, we are also convinced that the even the entire cash- receipt of Rs. 1,68,10,000/- cannot be treated as undisclosed income, only profit embedded therein should be treated as income. Since the net-profit rate of assessee was 8.46%, the net profit on Rs. 1,68,10,000/- comes to Rs. 14,22,126/-. The Ld. CIT(A) has also accepted this proposition on the basis of several judicial rulings mentioned by him in his order, which we agree without repeating here for the sake of brevity. Therefore, the Ld. CIT(A) was justified in arriving at the undisclosed income of Rs. 14,22,126/-. We further observe that the assessee has voluntarily offered undisclosed income of Rs. 32,00,000/- on this count, which is a fact not controverted by the revenue. Therefore, in such a situation, when the assessee had already offered undisclosed income of Rs. 32,00,000/- as against the income of Rs. 14,22,126/- computed by Ld. CIT(A), there was no scope for making any further addition. In view of these facts, we agree that no further addition was required to be made by Ld. AO. Hence the Ld. CIT(A) has rightly deleted the addition made by Ld. AO and we do not find any infirmity in the action of Ld. CIT(A). Accordingly, we also dismiss the Ground No. 3 of Revenue. 7. In the final result, this appeal of revenue is dismissed. Order pronounced as per Rule 34 of I.T.A.T. Rules, 1963 on 23/08/2022. Sd/- Sd/- (MADHUMITA ROY) (B.M. BIYANI) JUDICIAL MEMBER ACCOUNTANT MEMBER Indore Dated : 23.08.2022 Patel/Sr. PS M/s Vardhman Infra Estate P. Ltd. IT(SS)A No.30/Ind/2019 Assessment year 2016-17 Page 13 of 13 Copies to: (1) The appellant (2) The respondent (3) CIT (4) CIT(A) (5) Departmental Representative (6) Guard File By order UE COPY Sr. Private Secretary Income Tax Appellate Tribunal Indore Bench, Indore 1. Date of taking dictation 2. Date of typing & draft order placed before the Dictating Member 3. Date on which the approved draft comes to the Sr. P.S./P.S. 4. Date on which the fair order is placed before the Dictating Member for pronouncement 5. Date on which the file goes to the Bench Clerk 6. Date on which the file goes to the Head Clerk 7. Date on which the file goes to the Assistant Registrar for signature on the order 8. Date of dispatch of the Order