The ACIT, Circle-10, Ahmedabad V. Keyuriben Rakeshbhai Patel, Ahmedabad

MA 156/AHD/2010

• Counselvise Citation: [2012] 123 COUNSELVISE.COM (IT) 9587 (ITAT-AHMEDABAD)
• Duration Of Justice: 2 year(s) 5 month(s) 7 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 14-12-2012
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2003-2004
• Appeal Filed On: 07-07-2010
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: D K SINGH
• Keywords: Revised return

Judgement Text

, , , , IN THE INCOME TAX APPELLATE TRIBUNAL A BENCH, AHMEDABAD , . ! ' ,#$ # % BEFORE SHRI MUKUL KR.SHRAWAT, JUDICIAL MEMBER AND SHRI A. MOHAN ALANKAMONY, ACCOUNTANT MEMBER MA NOS.156 AND 173/AHD/2010 ( IN I.T.A. NOS.3766 & 3132/AHD/2007 RESPECTIVELY) ( ! & ! & ! & ! & / / / / ASSESSMENT YEAR : 2003-04 ) 1.ASST.CIT CIRCLE-10 AHMEDABAD 2.-DO- (ORIGINAL RESPONDENTS) ! ! ! ! / VS. 1. KEYURIBEN RAKESHBHAI PATEL NIRMA HOUSE ASHRAM ROAD,AHMEDABAD PAN: ACRPP 7524 P 2. RAJELBEN HIRENBHAI PATEL NIRMA HOUSE ASHRAM ROAD,AHMEDABAD PAN: AFIPP 0507 N (ORIGINAL APPELLANTS) ( #$ ./)* ./ PAN/GIR NO. : ( (+ / // / APPLICANTS ) .. ( ,-(+ / RESPONDENTS ) (+ . # / ASSESSEES BY : SHRI S.N.SOPARKAR, SR.ADV. WITH SHRI HIMANSHU SHAH ,-(+ / . # / REVENUE BY : SHRI D.K.SINGH, SR. D.R. !0 / 1$ / / / / DATE OF HEARING : 21/09/2012 2 & / 1$ / DATE OF PRONOUNCEMENT : 14/12/12 #3 / O R D E R PER SHRI MUKUL KR. SHRAWAT, JUDICIAL MEMBER : THESE TWO MISCELLANEOUS PETITIONS HAVE BEEN FILED BY THE REVENUE IN RESPECT OF THESE TWO ASSESSEES ON 7.7.2010 & 21. 7.2010 BOTH FOR ASSESSMENT YEAR 2003-04. SINCE THE FACTS AND CIRC UMSTANCES UNDER MA NOS.156 & 173/AHD/2010 (O/O ITA NOS.3766 & 3132/AHD/2007-RESPECTIVELY) & ACIT VS. SMT.KEYURIBEN RAKESHBHAI PATEL ACIT (OSD) VS. SMT.RAJALBEN HIRENBHAI PATEL ASST.YEAR 2003-04 - 2 - WHICH THESE TWO PETITIONS HAVE BEEN FILED BY THE R EVENUE WERE IDENTICAL, THEREFORE FOR THE SAKE OF CONVENIENCE CONSOLIDATED AND RELEVANT PORTION FROM ONE OF THE FILES IS REPRODUCED BELOW:- 2. THE ASSESSEE HAD FILED RETURN OF INCOME ORIGINA LLY ON 30/09/2003 DECLARING TOTAL INCOME OF RS.42,430/-. THEREAFTER, THE ASSESSEE FILED A REVISED RETURN ON 31/03/2004 DECLA RING TOTAL INCOME OF RS.42,84,770/- BY OFFERING THEREIN ADDITI ONAL INCOME OF RS.42,42,342/- OF INTEREST ON OFCPN (OPTIONAL FULLY CONVERTIBLE PREMIUM NOTES) OF NIRMA INDUSTRIES LTD. THE ASSESS ING OFFICER IN HIS ASSESSMENT ORDER BROUGHT TO TAX THE ACCRUED INT EREST OF RS.14,264/- ON BONDS OF REC ON THE BASIS OF BOARDS CIRCULAR NO.2/2002 DATED 15/02/2002. 3. THE LD. CIT(A) HAS CONFIRMED THE ADDITION OF RS .14,264/- AND OBSERVED THAT, SINCE THE OFCPN BONDS WERE ISSUED ON 07/06/2002 AND HENCE, THE BOARDS CIRCULAR NO.2/2002 DATED 15/ 02/2002 IS SQUARELY APPLICABLE. MOREOVER, THE LD.CIT(A) REJEC TED THE CLAIM OF THE ASSESSEE THAT ACCRUED INTEREST OF RS.42,42,3 42/- OFFERED BY THE ASSESSEE IN THE REVISED RETURN OF INCOME IN RES PECT OF OFCPN OF NIRMA LTD. IS NOT LIABLE TO TAX OBSERVING THAT, THE ASSESSEE HAS ALREADY OFFERED THE INTEREST IN THE REVISED RETURN OF INCOME. THE LD.CIT(A) HAS RELIED UPON THE DECISION OF HON'BLE S UPREME COURT IN THE CASE OF GOETZE (INDIA) LTD. V/S. CIT (2006) 284 ITR 323. 4. THE HONBLE ITAT HAS DELETED BOTH THE ABOVE ADD ITIONS I.E. ACCRUED INTEREST OF RS.14,264/- ON REC BONDS AND AC CRUED INTEREST OF RS.42,42,342/- OF OFCPN OF NIRMA LTD. R ELYING UPON THE HON'BLE ITATS DECISION IN THE CASE OF KISAN DI SCRETIONARY FAMILY TRUST IN ITA NO.1850/AHD/2007 DATED 02/11/20 07, NAVIN ASSOCIATES IN ITA NO.1248/AHD/2006 DATED 31/12/2008 , NAMAN ASSOCIATES IN ITA NO.1621/AHD/2007 DATED 04/04/2007 IGNORING THE FACTS OF THE CASE AND THE FINDING GIVEN BY THE LD.CIT(A). 5. IT IS UNDISPUTED FACT THAT, THE INVESTMENT IN B ONDS OF REC LTD. WAS MADE ON 13/09/2002 AND THE INVESTMENT OF OFCPN WAS MADE MA NOS.156 & 173/AHD/2010 (O/O ITA NOS.3766 & 3132/AHD/2007-RESPECTIVELY) & ACIT VS. SMT.KEYURIBEN RAKESHBHAI PATEL ACIT (OSD) VS. SMT.RAJALBEN HIRENBHAI PATEL ASST.YEAR 2003-04 - 3 - ON 25/03/2002 WHICH IS AFTER THE DATE OF ISSUE OF B OARDS CIRCULAR NO.2 OF 2002 DATED 15/02/2002. THEREFORE, THE PRIN CIPLES LAID DOWN IN THE BOARDS CIRCULAR NO.2/2002 ARE SQUARELY APPLICABLE IN THE PRESENT CASE. THE HONBLE ITAT HAS NOT APPR ECIATED THESE FACTS. 6. THE HONBLE ITAT HAS ALSO ERRED IN DELETING THE INTEREST INCOME OF RS.42,42,342/- FROM OFCPN WHICH WAS OFFE RED BY THE ASSESSEE HERSELF FOR TAXATION BY FILING REVISED RET URN OF INCOME AND NO OTHER REVISED RETURN WAS FILED FOR CLAIMING EXCL USION OF THAT INCOME. ACCORDINGLY, THE ASSESSEE IS ENTITLED FOR ANY SUCH CLAIM IN VIEW OF THE DECISION OF HON'BLE SUPREME COURT IN TH E CASE OF GOETZE (INDIA) LTD. V/S. CIT (2006) 284 ITR 323 (SC ). EVEN OTHERWISE, THE ACCRUED INTEREST FROM OFCPN IS TAXAB LE BY APPLYING THE PRINCIPLES OF BOARDS CIRCULAR NO.2/20 02 DATED 15/02/2002 FOR DEEP DISCOUNT BONDS ISSUED ON OR AFT ER 15/02/2002. THIS POSITION WAS ACCEPTED BY THE HON' BLE ITAT ITSELF IN THE CASE OF KISAN DISCRETIONARY FAMILY TRUST AND THE GIST OF ITS DECISION WAS REPRODUCED BY THE HON'BLE ITAT AT PARA .7, PAGE-4 OF ITS PRESENT ORDER, WHICH IS AS UNDER: THE LEARNED ACCOUNTANT MEMBER HAS ALSO AGREED WITH THIS FINDING OF THE LEARNED JUDICIAL MEMBER UNDER PARA.6 7 THAT, THE CIRCULAR IS APPLICABLE ONLY TO DEEP DISCOUNT BO NDS ACQUIRED ON OR AFTER 15/02/2002. 2. THE LD.SR.DR MR.D.K.SINGH HAS APPEARED AND INFOR MED THAT WHILE DECIDING THE ISSUE THE TRIBUNAL VIDE ORDERS DATED 2 2/5/2009 & 15/05/2009 RESPECTIVELY HAVE ERRED IN HOLDING THAT THE ACCRUED INTEREST ON INVESTMENT IN OFCPN OF NIRMA INDUSTRIES IS NOT TO B E TAXED FOR THE YEAR UNDER CONSIDERATION IN THE LIGHT OF THE BOARDS CIR CULAR NO.2/2002 DATED 15/02/2002 SPECIALLY WHEN THE INVESTMENT WAS MADE O N 25/03/2002, I.E. AFTER THE DATE OF THE CIRCULAR. THE LD.DR HAS PLEA DED THAT SINCE THE INVESTMENT WAS MADE AFTER THE DATE OF THE ISSUE OF BOARDS CIRCULAR, MA NOS.156 & 173/AHD/2010 (O/O ITA NOS.3766 & 3132/AHD/2007-RESPECTIVELY) & ACIT VS. SMT.KEYURIBEN RAKESHBHAI PATEL ACIT (OSD) VS. SMT.RAJALBEN HIRENBHAI PATEL ASST.YEAR 2003-04 - 4 - THEREFORE THE PRINCIPLE LAID DOWN IN THE SAID CIRCU LAR WAS SQUARELY APPLICABLE. ACCORDING TO LD.DR, THE TRIBUNAL HAS M ISTAKENLY FAILED TO APPRECIATE THOSE FACTS, THEREFORE ERRED IN ALLOWING THE CLAIM. THE MISTAKE BEING APPARENT DESERVES TO BE RECTIFIED. 3. ON THE OTHER HAND, FROM THE SIDE OF THE RESPONDE NT-ASSESSEE, THE LD.AR MR.S.N.SOPARKAR, SR.ADV. WITH SHRI HIMANSHU S HAH HAS PLACED RELIANCE ON A ORDER OF ITAT A BENCH AHMEDABAD DAT ED 8/10/2010, WHEREIN THE MISCELLANEOUS PETITION OF THE REVENUE I N GROUP OF CASES WAS DISMISSED; RELEVANT PORTION REPRODUCED BELOW:- 2. AT THE TIME OF HEARING OF THE AFORESAID MISCE LLANEOUS APPLICATIONS, SHRI R.K. DHANESTA, LD.SR.D.R. APPEAR ED ON BEHALF OF THE REVENUE AND CONTENDED THAT THE FACTS AND CIRCUMSTANCES UNDER WHICH ALL THE MISCELLANEOUS APPLICATIONS ARE FILED ARE IDENTICAL. THE LD.D.R. SUBMITTED THAT ITAT IN ITS ORDER DATED 18.098.2009 HAS NOT CO NSIDERED THE FACT THAT BONDS OF REC/OFCPNS WERE ISSUED AFTER 15.02.,2002. HE ALSO POINTED OUT THAT IN THIS ORDE R, THE ITAT HAS REFERRED TO THE DECISION OF ITAT IN THE CASE OF KISAN DISCRETIONARY FAMILY TRUST FOR THE ASSESSMENT YEAR 2003-04 AND ALSO OBSERVED THAT THE BOARDS CIRCULAR IS APPL ICABLE TO ALL THE INVESTMENTS MADE AFTER 15.02.2002. HOWEVER , TRIBUNAL HAS OBSERVED THAT ADMITTEDLY ALL THE INVES TMENTS IN SIX CASES ARE MADE PRIOR TO 15.02.2002. THIS OBSER VATION IS FACTUALLY INCORRECT, WHICH CAN BE SEEN FROM THE INV ESTMENTS GIVEN IN PARA 2 OF MISCELLANEOUS APPLICATIONS IN CA SE OF JETHIBEN K.PATEL DISCRETIONARY FAMILY TRUST, THEREF ORE, ACCRUED INTEREST IS TAXABLE IN THE HANDS OF THE ASS ESSEE ACCEPTED BY THE ITAT ITSELF. IN VIEW OF THE ABOVE, THE LD.D.R. POINTED OUT THAT THE ABOVE MISTAKE IS APPARENT FROM THE RECORD AND TRIBUNAL MAY RECALL ITS ORDER WITHIN THE MEANING MA NOS.156 & 173/AHD/2010 (O/O ITA NOS.3766 & 3132/AHD/2007-RESPECTIVELY) & ACIT VS. SMT.KEYURIBEN RAKESHBHAI PATEL ACIT (OSD) VS. SMT.RAJALBEN HIRENBHAI PATEL ASST.YEAR 2003-04 - 5 - OF SECTION 254(2) OF THE ACT AND DECIDE THE CASES O N MERIT ON THE BASIS OF FACTS MENTIONED THEREIN. 3. ON THE OTHER HAND, SHRI HIMANSHU SHAH, LD.COUNSEL APPEARING ON BEHALF OF THE ASSESSEES VEHEMENTLY POI NTED OUT THAT THERE IS NO MISTAKE APPARENT FROM THE RECORD W ITHIN THE MEANING OF SECTION 254(2). THE LD.COUNSEL OF THE A SSESSEE DREW OUR ATTENTION TO THE OPERATIVE PORTION OF THE ORDER OF TRIBUNAL DATED 18.09.2009, I.E. IN PARA 5, WHICH RE ADFS AS UNDER:- 5. WE HAVE GIVEN OUR CAREFUL CONSIDERATION TO THE RIVAL SUBMISSIONS MADE BEFORE US AND HAVE PERUSED THE ORDERS OF AUTHORITIES BELOW. WE HAVE ALSO GONE THROUGH THE EARLIER ORDER OF THIS TRIBUNAL IN ITA NO.1855/AHD/2007 DATED 02.11.2007 (SUPRA). IT IS PERTI9NENT TO NOTE THAT THE ITAT IN THE CASE OF KIS AN DISCRETIONARY FAMILY TRUST FOR THE ASSESSMENT YEAR 2003-04 AND RAKESHBHAI K.PATEL FOR THE ASSESSMENT YEAR 2004-05 HAS HELD THAT METHOD OF ACCOUNTING SHOULD BE TAKEN AS CASH SYSTEM AND NOT MERCANTILE SYSTEM. THE FACTS OF ALL THE CASES BEFORE US ARE IDENTICAL WITH THE FACTS OF CASES DECIDED BY ITAT I ITA NO.1855/AHD/2007 DATED 02.11.2007 (SUPRA). THEREFRE, IN OUR CONSIDERED OPINION, THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) IS LEGALLY AND FACTUALLY CORRECT TO DIRECT THE A.O. TO ADOPT CASH METHOD OF ACCOUNTING IN THE CASE OF ALL THE ASSESSE ES. WITH REGARD TO DELETION OF ACCRUED INTEREST ON OFCP NOTES & BONDS OF REC & PNS OF ADESH FINSTOCK (P) LTD., ETC., THE A.O. ASSESSED THE INCOME ON MERCANT ILE BASIS ON THE BASIS OF CIRCULAR NO.2 OF 2002 DATED 15.02.2002. THE ITAT IN THE CASE OF KISAN DISCRETIONARY FAMILY TRUST IN ITA NO.1850/AHD/2007, ORDER DATED 02.11.2007 FOR THE ASSESSMENT YEAR 2003-04 HAS HELD THAT THIS CIRCULAR MA NOS.156 & 173/AHD/2010 (O/O ITA NOS.3766 & 3132/AHD/2007-RESPECTIVELY) & ACIT VS. SMT.KEYURIBEN RAKESHBHAI PATEL ACIT (OSD) VS. SMT.RAJALBEN HIRENBHAI PATEL ASST.YEAR 2003-04 - 6 - CANNOT BE APPLIED IN RESPECT OF THOSE ASSESSEES, WH O ARE FOLLOWING THE CASH SYSTEM OF ACCOUNTING AND ALS O IN RESPECT OF SECURITIES ISSUED PRIOR TO 15.02.2002 . ADMITTEDLY SECURITIES IN ALL THE ASSESSES BEFORE US WERE ISSUED PRIOR TO 15.02.2002. THEREFORE, BY CONSIDERING THE TOTALITY OF THE FACTS AND CIRCUMSTA NCES OF THE CASE, WE DO NOT FIND ANY INFIRMITY IN THE OR DER OF LEARNED COMMISSIONER OF INCOME TAX (APPEALS) FOLLOWING THE DECISION OF ITAT, A BENCH, AHMEDABAD IN THE CASE OF KISAN DISCRETIONARY FAMILY TRUST AND DIRECT THE A.O. TO DELETE THE ADDITION OF ACCRUED INTEREST. AS A NATURAL COROLLARY, IF THE I NCOME IS ASSESSED ON ACCRUAL BASIS IN EARLIER YEARS, THEN A.O. WILL EXCLUDE THE SAME IN THE YEAR OF RECEIPT. 3.1. THE LD.COUNSEL FO THE ASSESSEE SUBMITTED THAT FROM THE PERUSAL OF THE AFORESAID PARA, IT IS CLEAR THAT TH E LEARNED COMMISSIONER OF INCOME TAX (APPEALS) DIRECTED THE A SSESSING OFFICER TO ADOPT CASH METHOD OF ACCOUNTING IN THE C ASE OF ALL THE ASSESSEES. THEREFORE, IT WILL NOT MAKE ANY DIFFERE NCE WHETHER THE INVESTMENTS WERE MADE IN THE BONDS OF REC/OFCPN ECH OLAC FINVEST, OFCPN SUNRISE FINCAP LTD. PRIOR TO 15.02.2 002 OR AFTER THAT DATE. THIS ASPECT HAS BEEN DULY CONSIDERED BY THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) AND WHOSE ORDE R HAS BEEN UPHELD BY THE TRIBUNAL IN ITS ORDER DATED 18.09.200 2. FINALLY, THE LD.COUNSEL OF THE ASSESSEE SUBMITTED THAT UNDER SEC TION 254(2), TRIBUNAL HAS NOT POWER TO REVIEW ITS OWN ORDER. BY THESE MISCELLANEOUS APPLICATIONS, THE REVENUE IS MERELY S EEKING REVIEW, WHICH IS NOT PERMISSIBLE UNDER SECTION 254(2) OF TH E ACT. HE ACCORDINGLY SUBMITTED THAT MISCELLANEOUS APPLICATIO NS FILE BY THE REVENUE BE DISMISSED. 4. HAVING HEARD BOTH THE SIDES, WE HAVE CAREFULLY G ONE THROUGH ALL THE MISCELLANEOUS APPLICATIONS. THE AL LEGED MISTAKE POINTED OUT IS THAT TRIBUNAL HAS NOT CONSIDERED THA T BONDS OF REC/OFCPN WERE ISSUED AFTER 15.02.2002. ON PERUSAL OF THE MA NOS.156 & 173/AHD/2010 (O/O ITA NOS.3766 & 3132/AHD/2007-RESPECTIVELY) & ACIT VS. SMT.KEYURIBEN RAKESHBHAI PATEL ACIT (OSD) VS. SMT.RAJALBEN HIRENBHAI PATEL ASST.YEAR 2003-04 - 7 - ORDER OF LEARNED COMMISSIONER OF INCOME TAX (APPEAL S), WHICH IS CONFIRMED BY THE TRIBUNAL, IT CAN BE SEEN THAT DATE OF PURCHASE OF REC/OFCPN HAS BEEN DULY CONSIDERED. THIS IS EVIDEN T FROM THE FACT THAT TRIBUNAL HAS MERELY FOLLOWED THE DECISION OF KISAN DISCRETIONARY FAMILY TRUST FOR THE ASSESSMENT YEAR 2003-04 AND RAKESHBHAI K.PATEL FOR THE ASSESSMENT YEAR 2004-05 WHEREIN ALSO DATE OF PURCHASE WAS AFTER 15.02.2002 AND HELD THAT METHOD OF ACCOUNTING SHOULD BE TAKEN AS CASH SYSTEM AND NOT M ERCANTILE SYSTEM. ON THIS BASIS, TRIBUNAL HAS UPHELD THE V IEW TAKEN BY THE LEARNED COMMISSIONER OF INCOME TAX (APPEALS) IN RES PECT OF ALL THE ASSESSEES. WE ARE, THEREFORE, OF THE VIEW THAT THERE IS NO MISTAKE APPARENT FROM THE RECORD WITHIN THE MEANING OF SECTION 254(2) OF THE ACT. IT IS WELL SETTLED LAW THAT UND ER SECTION 254(2), NEITHER THE DEPARTMENT NOR THE ASSESSEE HAS POWER T O RE-ARGUE ITS CASE BY FURNISHING FRESH EVIDENCE. UNDER SECTION 2 54(2) TRIBUNAL HAS NO POWER TO REVIEW ITS ORDER. BY THE PRESENT M ISCELLANEOUS APPLICATIONS, THE DEPARTMENT IS MERELY SEEKING REVI EW OF ORDER OF THE TRIBUNAL, WHICH IS NOT PERMISSIBLE. 6. IN VIEW OF THE FOREGOING DISCUSSION, WE ARE CO NVINCED THAT THERE CANNOT BE ANY DISPUTE WITH THE PROPOSITION TH AT POWER UNDER SUB-SECTION (2) OF SECTION 254 IS TO RECTIFY THE MI STAKE APPARENT FROM THE RECORD, BUT THAT POWER DOES NOT CLOTHE THE TRIBUNAL WITH THE JURISDICTION TO REVIEW OF ITS EARLIER ORDER OR RE-WRITE A FRESH JUDGMENT. BY PRESENT MISCELLANEOUS APPLICATIONS RE VENUE VIRTUALLY SEEKING REVIEW, THEREFORE, ALL THE MISCEL LANEOUS APPLICATIONS FILED BY THE REVENUE ARE DISMISSED. 4. HAVING HEARD THE SUBMISSIONS OF BOTH THE SIDES, WE ARE OF THE CONSIDERED VIEW THAT ONCE THE RESPECTED CO-ORDINATE BENCH IN IDENTICAL SITUATION HAS ALREADY DISMISSED THE MISCELLANEOUS P ETITION OF THE REVENUE, THEREFORE JUDICIAL DISCIPLINE REQUIRES TO FOLLOW SUCH JUDGEMENT PASSED BY RESPECTED CO-ORDINATE BENCH. THEREFORE, THE LEGAL ISSUE STATED TO BE THE MISTAKE APPARENT AS RAKED-UP BY TH E REVENUE DEPARTMENT MA NOS.156 & 173/AHD/2010 (O/O ITA NOS.3766 & 3132/AHD/2007-RESPECTIVELY) & ACIT VS. SMT.KEYURIBEN RAKESHBHAI PATEL ACIT (OSD) VS. SMT.RAJALBEN HIRENBHAI PATEL ASST.YEAR 2003-04 - 8 - NOW STOOD COVERED BY THIS PRECEDENT IN FAVOUR OF T HE ASSESSEE, THEREFORE THESE PETITIONS OF THE REVENUE ARE HEREBY DISMISSED . 5. IN THE RESULT, BOTH THE MISCELLANEOUS APPLICATIO NS FILED BY THE REVENUE ARE DISMISSED. SD/- S D/- ( . ! ' ) ( ) #$ ( A. MOHAN ALANKAMONY ) ( MUKUL KR. SHRAWAT ) ACCOUNTANT MEMBER JUDICIA L MEMBER AHMEDABAD; DATED 14/ 12 /2012 41..!, .!../ T.C. NAIR, SR. PS #3 / ,5 6#5& #3 / ,5 6#5& #3 / ,5 6#5& #3 / ,5 6#5&/ COPY OF THE ORDER FORWARDED TO : 1. (+ / THE TWO ASSESSEES 2. ,-(+ / THE REVENUE 3. 7 / CONCERNED CIT 4. 7() / THE CIT(A)-II, AHMEDABAD 5. 5:; ,! , , / DR, ITAT, AHMEDABAD 6. ;< =0 / GUARD FILE. #3! #3! #3! #3! / BY ORDER, -5 , //TRUE COPY// > >> >/ // / ) ) ) ) ( DY./ASSTT.REGISTRAR) , , , , / ITAT, AHMEDABAD 1. DATE OF DICTATION ON 7.12.12 (DICTATION-PAD PAGES 5 ATTACHED) 2. DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 10.12.12 OTHER 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 D ICTATING MEMBER FOR PRONOUNCEMENT 5. DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR.P .S./P.S14.12.12 6. DATE ON WHICH THE FILE GOES TO THE BENCH CLERK 14.12.12 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