Ajit Jain, New Delhi V. ITO Ward 28 (3), New Delhi

MA 417/DEL/2017

• Counselvise Citation: [2020] 110 COUNSELVISE.COM (IT) 0618 (ITAT-DELHI)
• Duration Of Justice: 3 year(s) 5 month(s) 4 day(s)
• Appeal Type: Miscellaneous Application
• Pronouncement Date: 21-12-2020
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: E
• Assessment Year: 1998-1999
• Appeal Filed On: 17-07-2017
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Keywords: Opportunity of being heard; Corroborative evidences; Accommodation entries; Set aside
• Section: 143(3); 158BC; 68

Judgement Text

PAGE | 1 INCOME TAX APPELLATE TRIBUNAL DELHI BENCH FRIDAY: NEW DELHI BEFORE SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER (THROUGH VIDEO CONFERENCING) M.A. NO. 417/DEL/2017 ( IN ITA. NO.4200/DEL/2006 ) (ASSESSMENT YEAR:1998-99) AJIT PRASAD JAIN, 1037, TILAK BAZAR CHOWK, DELHI. PAN: ADHPJ4956A VS. ITO , WARD : 28 (3) NEW DELHI. A N D M.A. NO. 418/DEL/2017 ( IN ITA. NO. 4199/DEL/2006 ) (ASSESSMENT YEAR: 1998-99) AJIT PRASAD JAIN & SONS [ HUF ] 1037, TILAK BAZAR CHOWK, DELHI. PAN: AADHA2545P VS. ITO, WARD : 28 (3) NEW DELHI. (APP LICANT S ) (RESPONDENT) ASSESSEE BY : SHRI K. S AMPATH , ADV OCATE; & SHRI RAJ KUMAR, ADVOCATE. REVENUE BY: NONE . DATE OF HEARING 16 /1 0 / 2020 DATE OF PRONOUNCEMENT 21 / 1 2 / 2020 O R D E R PER PRASHANT MAHARISHI, A. M. 1. THESE ARE THE TWO MISCELLANEOUS APPLICATION FILED BY THE ASSESSEE AND HIS HUF FOR THE SAME YEAR AND OF THE SAME ORDER OF COORDINATE BENCH. 2. THIS MISCELLANEOUS APPLICATION NO. 417/DEL/2017 IS FILED BY THE ASSESSEE IN ITA. NO. 4200/DEL/2006 WHEREIN THE ASSESSEE HAS CHALLENGED THE SAME ON THE FOLLOWING GROUNDS:- PAGE | 2 2. DURING THE COURSE OF THE HEARING OF APPEAL IT WAS POINTED OUT TO THE HONBLE TRIBUNAL SPECIFICALLY THAT THE VERY SAME ORDER OF THE CIT(A) AS IMPUGNED BY THE REVENUE HAD BEEN SIMILARLY APPEALED AGAINST TO THE TRIBUNAL IN THE CASE OF SANJEEV & SONS HUF (ITA NO. 362/DEL/2007) FOR THE ASSESSMENT YEAR 1998-99. THE TRIBUNAL IN THAT CASE DID NOT FIND ANY ERROR IN THE ORDER OF THE CIT(A) AND DISMISSED THE REVENUES APPEAL. IT WAS ALSO POINTED OUT TO THE HONBLE TRIBUNAL DURING THE HEARING THAT IN SIMILAR CIRCUMSTANCES THE TRANSACTION OF SALE OF JEWELLERY BY THE ASSESSEE DECLARED EARLIER THROUGH THE VDIS AND SOLD TO BISHAN CHAND MUKESH KUMAR HAD BEEN FOUND TO BE GENUINE BY THE ALLAHABAD HIGH COURT IN CIT VS. MOHAN LAI AGARV/AL (2013) 217 TAXMAN 29. IT WAS ALSO POINTED OUT THAT THE FINDING IN BOTH THE CITED APPELLATE ORDERS WERE THAT MANOJ KUMAR HAD NOTHING TO DO WITH THE FIRM M/S BISHAN CHAND MUKESH KUMAR. 3. THAT HAVING BEEN DONE THE ONLY OPTION BEFORE THE TRIBUNAL IN THE SUBJECT CASE IN THE ABOVE APPEAL WAS TO HAVE FOLLOWED THE ORDER OF THE CO-ORDINATE BENCH IN SANJEEV & SONS HUF AND ALSO OF THE ALLAHABAD HIGH COURT IN MOHAN LAI AGARWAL AS CITED SUPRA. IF THE TRIBUNAL FOR ANY REASON HAD FOUND IT NOT POSSIBLE FOR IT TO GO BY THE CONCLUSIONS OF THE TRIBUNAL OR THE HONBLE HIGH COURT CASES AS CITED BEFORE IT AND HAD A DIFFERENT VIEW ON IT THEN THE TRIBUNAL WAS BOUND TO REFER THE MATTER TO THE PRESIDENT CITING ITS DIFFERENCE OF VIEW WITH THE DECIDED CASES AND OUGHT TO HAVE RECOMMENDED THE SETTING UP OF A SPECIAL BENCH TO HEAR THE CONTROVERSY. INSTEAD THE TRIBUNAL HAS TOTALLY IGNORED THESE CITATIONS AND ADOPTED AN INDEPENDENT APPROACH WHICH IS LAW IT COULD NOT HAVE SO DONE. BY DOING SO THE TRIBUNAL NOT ONLY VIOLATED THE PRINCIPLE OF PRECEDENCE AS REPEATEDLY EMPHASIZED FOR OBSERVATION AND ADOPTION BY DIFFERENT BENCHES OF THE HIGH COURT AND THE SUPREME COURT BUT ALSO COMMITTED THE IMPROPRIETY OF NOT OPINING TO FOLLOWING THE HIGH COURT DECISION ON THE POINT FROM ALLAHABAD WHICH, IN THE ABSENCE OF ANY CASE TO THE CONTRARY WAS BINDING ON IT. 4. BESIDES THERE ARE THE FOLLOWING GLARING MISTAKES IN THE IMPUGNED ORDER: I. THAT THE AO HIMSELF HAD ONLY MADE A PASSING MENTION OF A SEARCH IN THE CASE OF BISHAN CHAND MUKESH KUMAR. THE AO HIMSELF HAD NOT RELIED UPON ANY OBSERVATION OR FINDING IN THE CASE OF BISHAN CHAND MUKESH KUMAR IN THE SECTION 158BC PROCEEDINGS. IN SUCH CIRCUMSTANCES IT WAS NOT AT ALL NECESSARY FOR THE RESPONDENT-ASSESSEE TO WHISPER EVEN A SINGLE WORD' ON THE FATE OF THOSE PROCEEDINGS IN THE SUBJECT APPEAL. THE OBSERVATION OF THE HON'BLE TRIBUNAL IS THUS EX FACIE ERRONEOUS. II. THE HONBLE TRIBUNAL FAILED TO APPRECIATE THAT THE HON'BLE HIGH COURT ORDER WAS A GENERAL REMAND FOR VERIFICATION OF THE SALES BY BISHAN CHAND MUKESH KUMAR AND NOT A SPECIFIC AND ISOLATED DIRECTION TO DO SO EXCLUSIVELY IN THE CASE OF THE ASSESSEE. ONCE, IN TERMS OF THAT REMAND ORDER, THE POINT AS TO THE GENUINENESS OF THE PURCHASE STOOD GENERALLY VERIFIED IN THE GROUP CASES ON SEPARATE AND EXCLUSIVE VERIFICATION TO THE EXCEPTION OF THE OTHER CASES WAS WARRANTED. OBSERVATIONS MADE IN THIS BEHALF IN PARA 8 ARE EX FACIE ERRONEOUS AND UNWARRANTED. III. THAT THE HON'BLE TRIBUNAL IN THE INSTANT CASE HAD NEITHER THE AUTHORITY NOR THE JURISDICTION TO GET INTO THE AFFAIRS OF BISHAN CHAND MUKESH KUMAR ON THE ASPECT OF THE SALES-TAX STATUTE. OBSERVATIONS MADE IN THIS CONTEXT BY THE HON'BLE TRIBUNAL IN PARA 7.1 OF THE IMPUGNED ORDER IS ERRONEOUS AND OTIOSE.THAT APART THE SALES TAX ASSESSMENT ORDER IS NEVER A TRANSACTION BY TRANSACTION REPORT OF SALES OF THE ASSESSEE. THE HONBLE TRIBUNAL HAS MISUNDERSTOOD THE FORM AND CONTENT OF THE SALES TAX ASSESSMENT ORDER AND SO OBSERVATION MADE IN THIS CONTEXT ARE PAGE | 3 INCONGRUOUS AND FALLACIOUS. IV. THAT THE SUMMONING OF THE PURCHASER (AFTER 19 YEARS) WAS NOT THE SOLE OR PROPER METHOD FOR ASCERTAINING THE GENUINENESS OF THE TRANSACTION. THERE WAS A PLETHORA OF OTHER COLLATERAL EVIDENCE INCONTROVERTIBLY POINTING OUT TO THE GENUINENESS OF THE TRANSACTION. V. THAT THE CITED ORDER OF THE HONBLE TRIBUNAL IN THE CASE OF SANJEEV KUMAR & SONS WAS PASSED BY THE HON'BLE TRIBUNAL POST THE REMAND BY THE HONBLE HIGH COURT. THE HON'BLE TRIBUNAL IN THAT APPEAL DID NOT AT ALL FIND THE PREPOSITIONS AS COUCHED IN THE SUBJECT APPEAL RELEVANT OR IMPERATIVE BECAUSE THEY WERE APPARENTLY SUPERFLUOUS AND UNNECESSARY. 3. THE LD. AUTHORISED REPRESENTATIVE REITERATED THE SAME FACTS AS STATED IN ITS MISC. APPLICATION. 4. THE LD. DEPARTMENTAL REPRESENTATIVE VEHEMENTLY OPPOSED THE ABOVE MISC. APPLICATION STATING THAT THE ORDER HAS BEEN PASSED BY THE CO-ORDINATE BENCH AFTER CONSIDERING ALL THE FACTS AND ON THE BASIS OF THE DECISION OF THE JURISDICTIONAL HONBLE HIGH COURT. IT WAS FURTHER STATED THAT THE DECISION RELIED UPON OF ITO VS. SANJEEV KUMAR & SONS HAS ALREADY BEEN CONSIDERED BY THE CO-ORDINATE BENCH. IT WAS ALSO STATED THAT THE ASSESSEE SHOULD NOT HAVE BEEN AGGRIEVED BY THE ORDER OF THE CO-ORDINATE BENCH WHEREIN THE MATTER IS SET ASIDE TO THE FILE OF THE LD. ASSESSING OFFICER FOR DECIDING THE ISSUE AFRESH. 5. WE HAVE CAREFULLY CONSIDERED THE RIVAL CONTENTIONS AND PERUSED THE ORDERS OF THE CO-ORDINATE BENCH. THE CO-ORDINATE BENCH HAS DECIDED THIS ISSUE IN PARA NOS. 5 ONWARDS OF ITS ORDER AS UNDER :- 5. WE HAVE HEARD AND CONSIDERED THE SUBMISSIONS OF BOTH THE PARTIES AND HAVE GONE THROUGH THE ENTIRE MATERIAL AVAILABLE ON RECORD. FROM THE DIRECTIONS OF HONBLE JURISDICTIONAL HIGH COURT, AS REPRODUCED ABOVE, THE TRIBUNAL IS REQUIRED TO EXAMINE AS TO WHETHER THE ALLEGED TRANSACTION OF SALE OF JEWELLERY WAS GENUINE OR NOT AND TO RETURN ITS FINDING THEREAT. 6. A PERUSAL OF IMPUGNED ORDER REVEALS THAT ONE OF THE ASSESSEE'S STANDS HAS BEEN THAT THE FIRM M/S. BISHAN CHAND MUKESH KUMAR IS ASSESSED TO TAX REGULARLY AND FOR THE INSTANT YEAR THE ASSESSMENT WAS COMPLETED U/S. 143(3) ACCEPTING THE TURNOVER DECLARED BY IT. HOWEVER, THE FACT REMAINS THAT ASSESSMENT IN THE CASE OF M/S. BISHAN CHAND MUKESH KUMAR HAS ALSO BEEN SUBSEQUENTLY MADE U/S. 158BC OF THE ACT, WHICH HAS BEEN TAKEN INTO PAGE | 4 ACCOUNT BY THE AO IN THE INSTANT PROCEEDINGS. THE ASSESSEE HAS NOT WHISPERED EVEN A SINGLE WORD ON THESE PROCEEDINGS SUBSEQUENTLY TAKEN AGAINST THE ALLEGED PURCHASER U/S. 158BC OF THE ACT. HENCE, THIS STAND OF ASSESSEE DOES NOT RENDER ANY SUPPORT TO THE CASE OF THE ASSESSEE. 7. THE OTHER STAND OF THE ASSESSEE IN BOTH THESE CASES HAS ALSO BEEN THAT THE SALES TAX ASSESSMENT OF M/S. BISHAN CHAND MUKESH KUMAR FOR THE YEAR WAS COMPLETED ON THE TURNOVER OF RS.134 CRORES AND THE TRANSACTION OF SALE OF JEWELLERY WAS CONFIRMED BY WAY OF AFFIDAVIT OF SH. BISHAN CHAND AND ALL THESE DOCUMENTARY EVIDENCES/ORDERS WERE SUBMITTED BEFORE THE AO. HOWEVER, ON PERUSAL OF THE ASSESSMENT ORDER OF ASSESSEE (HUF) SHOWS THAT THAT THE AO HAS RECORDED FOLLOWING CATEGORICAL FINDING : ' THE ASSESSEE WAS REQUIRED TO FURNISH DOCUMENTARY EVIDENCE TO THE SALE OF THIS JEWELLERY AS ALSO BOOKS OF ACCOUNTS, VOUCHERSAND BANK PASSBOOK, A NUMBER OF OPPORTUNITIES WERE G IVEN TO THE ASSESSEEBUT THE ASSESSEE FAILED TO FURNISH ANY INFORMATION OR SUPPORTING EVIDENCE. THEASSESSEE WAS SPECIFICALLY ASKED TO FURNISH EVIDENCE TO THE ACQUISITION OF THE ABOVE SAID JEWELLERY. IN THE ABSENCE OF ANY EVIDENCE, I HAVE REASON TO BELIEF THAT THIS IS ACCOMMODATION ENTRY AND HAS BEEN ROUTED THROUGH A SALE BILL BY OBTAINING DRAFT/CHEQUE AGAINST PAYMENT OF CASH FROM M/S. BISHAN CHAND MUKESH KUMAR .' 7.1 IN VIEW OF THE ABOVE CONTRADICTIONS, IT IS NOT PROPER TO RECORD A DECISIVE FINDING BASED ON EXAMINATION OF SUCH EVIDENCES, ALLEGED TO HAVE BEEN PRODUCED BEFORE THE AO. SECONDLY, THE SALES TAX ASSESSMENT ORDER OF M/S. BISHAN CHAND MUKESH KUMAR FOR THE RELEVANT YEAR, PLACED IN THE PAPER BOOK BEFORE US, NOWHERE REVEALS THAT THE ALLEGED SALE OF JEWELLERY MADE BY THE ASSESSEE ARE INCLUDED IN THE GROSS TURNOVER DECLARED TO THE SALES TAX AUTHORITIES OR NOT NOR ANY SUCH FACT IS WRITTEN IN THE SAID SALES TAX ASSESSMENT ORDER. THIS FACT CANNOT BE ASCERTAINED BY THE TRIBUNAL UNLESS THE LIST OF TOTAL PURCHASES SUBMITTED BEFORE THE SALES TAX AUTHORITIES IS PLACED ON RECORD BEFORE US FOR EXAMINATION TO ASCERTAIN WHETHER THE PURCHASES ALLEGEDLY MADE FROM THE ASSESSEE WERE DECLARED BY THE PURCHASER BEFORE THE SALES TAX AUTHORITIES. HOWEVER, NO SUCH LIST OF PURCHASE SUBMITTED BEFORE THE CONCERNED SALES TAX AUTHORITIES, IS AVAILABLE HERE ON RECORD. SECONDLY, IT IS ALSO NOT CLEARLY PROVED BY ANY EVIDENCE THAT THE PURCHASE VOUCHERS PLACED BEFORE US ALSO FORMED THE PART OF PURCHASE VOUCHERS PLACED BEFORE THE SALESTAX AUTHORITIES ASCERTAINING THE FACT THAT THE IMPUGNED SALE OF JEWELLERY WAS INCLUDED IN THE PURCHASES OF BISHAN CHAND MUKESH KUMAR DECLAREDBEFORE THE SALES TAX AUTHORITIES. THIS ASPECT OF THE CASE NEEDS THOROUGH EXAMINATION AT THE STAGE OF ASSESSING OFFICER FROM THE RECORDS OF SALES TAX AUTHORITIES AND FROM BOOKS OF PURCHASER BEFORE FINALLY DECIDING THE ISSUE AS PER DIRECTIONS OF THE HON'BLE HIGH COURT. 8. THE CONTENTION OF THE ASSESSEE IS ALSO THAT THE IMPUGNED JEWELLERY WAS DECLARED IN VDIS, 1997. THIS FACT IS EVIDENT FROM THE DOCUMENTARY EVIDENCE PLACED BY THE ASSESSEE AND IS WELL RECORDED IN THE ORDERS OF THE AUTHORITIES BELOW. HOWEVER, IT IS NOT THE STAND OF THE ASSESSEE BEFORE US THAT THE FACTUM OF DECLARATION OF JEWELLERY IN VDIS, 1997 WAS NOT THERE BEFORE THE HON'BLE JURISDICTIONAL HIGH COURT BEFORE THE MATTER HAS BEEN RESTORED BACK TO THE TRIBUNAL FOR EXAMINATION OF ACTUAL SALE TRANSACTIONS MADE BY THE ASSESSEE. THEREFORE, IN VIEW OF EXPRESS DIRECTIONS OF HONBLE JURISDICTIONAL HIGH COURT TO EXAMINE THE ACTUAL SALE TRANSACTIONS MADE BY ASSESSEE, THE DECISIONS PAGE | 5 RELIED BY THE ASSESSEE RENDER NO SUPPORT TO THE ASSESSEE IN THE PECULIAR FACTS AND CIRCUMSTANCES OF THE INSTANT CASE. 9. THE OTHER STAND TAKEN BY THE ASSESSEE HAS ALSO BEEN THAT SOME OF THE ASSESSING OFFICERS AT AMRITSAR, DELHI AND MATHURA HAVE SUMMONED SHRI BISHAN CHAND AND HE IN HIS STATEMENTS HAD CONFIRMED THE- PURCHASE OFJEWELLERY AND DENIED THAT THEY ARE PROVIDING ONLY ACCOMMODATION ENTRIES. HOWEVER, HERE WE FIND THAT THE ID. ASSESSING OFFICER APPEARS TO HAVE NOT SUMMONED THE SAID PURCHASER FOR VERIFICATION OF THE ACTUAL PURCHASE/SALE TRANSACTION OF THE IMPUGNED JEWELLERY. THEREFORE, BEFORE REPUDIATING THIS STAND OF THE ASSESSEE, THE AO IS REQUIRED TO SUMMON THE ALLEGED PURCHASER OF IMPUGNED JEWELLERY AND TO RECORD ITS STATEMENT TO ASCERTAIN THE TRUTH. ALL THESE EXERCISES ARE NECESSARY TO BE MADE BEFORE DECIDING THE ISSUE IN VIEW OF THE DIRECTIONS OF HON'BLE JURISDICTIONAL HIGH COURT. SUCH EXERCISES/ENQUIRIES, BEING NOT POSSIBLE AT THE STAGE OF TRIBUNAL, CAN BE CONDUCTED AT THE STAGE OF ASSESSING OFFICER WELL. THE ID. AR WAS ASKED IF HE HAS ANY OTHER EVIDENCE TO ESTABLISH THAT THE IMPUGNED SALE OF JEWELLERY IS RECORDED IN ANY OF BOOKS OF A/C OF PURCHASER, BUT HE SHOWED HIS INABILITY TO PRESENTLY ADDUCE ANY SUCH DIRECT EVIDENCE BEFORE US. ON THE OTHER HAND, THE ID. DR ALSO COULD NOT PROVE BY ANY POSITIVE EVIDENCE TO ESTABLISH THAT THE IMPUGNED SALE OF JEWELLERY WAS NOT RECORDED IN AND VERIFIABLE FROM THE BOOKS OF ALLEGED PURCHASER. IN PRESENT OF ALL THESE FACTS, WE, THEREFORE, THINK IT APPROPRIATE IN THE INTEREST OF JUSTICE TO RESTORE THE ISSUE BACK TO THE FILE OF ASSESSING OFFICER FOR DECIDING THE SAME AFTER VERIFYING THE ACTUAL PURCHASE / SALE TRANSACTION & STOCK ENTRY OF IMPUGNED JEWELLERY FROM THE BOOKS OF ACCOUNTS OF THE PURCHASER, RECORDS OF CONCERNED SALES TAXAUTHORITIES AND IF NEED BE, BY SUMMONING THE PURCHASER FOR EXAMINATION AND ALSO BY CONSIDERING ALL THE STANDS TAKEN BY THE ASSESSEE BEFORE THE AUTHORITIES BELOW. NEEDLESS TO SAY, THE ASSESSEE SHALL BE GIVEN REASONABLE OPPORTUNITY OF BEING HEARD BEFORE DECIDING THE ISSUE ON MERITS IN THE LIGHT OF OBSERVATIONS MADE BY US AS ABOVE. ACCORDINGLY, THE APPEAL OF THE REVENUE IS ALLOWED FOR STATISTICAL PURPOSES. 10. SINCE, THE FACTS AND CIRCUMSTANCES INVOLVED IN APPEAL OF REVENUE (ITA NO. 4199/DEL./2006) IN THE CASE OF AJIT PRASAD JAIN & SONS (HUF) ARE QUITE IDENTICAL ON THE ISSUE OF BOGUS SALE CONSIDERATION OF JEWELLERY TO M/S. BISHAN CHAND MUKESH KUMAR ADDED U/S. 68 OF THE ACT, OUR DECISION TAKEN IN ITANO. 4200/DEL./2006, AS ABOVE, WILL EQUALLY APPLY TO THIS APPEAL ALSO. ACCORDINGLY, THIS APPEAL OF THE REVENUE ALSO STANDS ALLOWED FOR STATISTICAL PURPOSES. 6. IN PARA NO. 4 OF THE ORDER THE CO-ORDINATE BENCH , IT HAS NOTED THE DECISION CITED BEFORE IT IN THE CASE OF ITO VS. SANJEEV KUMAR & SONS [HUF]. THE DECISION OF THE CO-ORDINATE BENCH IS PURSUANT TO THE DIRECTION OF HONBLE JURISDICTIONAL HIGH COURT. THE CO-ORDINATE BENCH HAS FURTHER NOTED THAT THE ASSESSING OFFICER HAS NOT SUMMONED THE PURCHASER FOR ACTUAL PURCHASE OF JEWELLERY AND THAT IS THE DIRECTION OF THE HONBLE HIGH COURT. IN VIEW OF THIS, WE DO NOT FIND ANY INFIRMITY IN THE ORDER OF THE CO-ORDINATE BENCH WHICH IS BASED ON THE SPECIFIC DIRECTION OF THE JURISDICTIONAL HIGH COURT. IN VIEW OF THIS, M.A. NO. 417/DEL/2017 FOR ASSESSMENT YEAR 1998-99 IS DISMISSED. PAGE | 6 7. SIMILAR ARE THE FACTS IN THE CASE OF THE HUF OF THE ASSESSEE IN M.A. NO. 418/DEL/2017 FOR ASSESSMENT YEAR 1998-99. THEREFORE, FOR THE SIMILAR REASONS THAT MISC. APPLICATION IS ALSO DISMISSED. 8. ACCORDINGLY BOTH THE MISCELLANEOUS APPLICATIONS ARE DISMISSED. ORDER PRONOUNCED IN THE OPEN COURT ON : 21/12/2020. SD/- SD/- (SUDHANSHU SRIVASTAVA) (PRASHANT MAHARISHI) JUDICIAL MEMBER ACCOUNTANT MEMBER DATED : 21/12/2020 *MEHTA* COPY FORWARDED TO 1. APPLICANT 2. RESPONDENT 3. CIT 4. CIT (A) 5. DR:ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI. DATE OF DICTATION 1 0 .1 2 .2020 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE DICTATING MEMBER 1 0 .1 2 .2020 DATE ON WHICH THE TYPED DRAFT IS PLACED BEFORE THE OTHER MEMBER 21 .1 2 .2020 DATE ON WHICH THE APPROVED DRAFT COMES TO THE SR. PS/ PS 21 .1 2 .2020 DATE ON WHICH THE FAIR ORDER IS PLACED BEFORE THE DICTATING MEMBER FOR PRONOUNCEMENT 21 .1 2 .2020 DATE ON WHICH THE FAIR ORDER COMES BACK TO THE SR. PS/ PS 21 .1 2 .2020 DATE ON WHICH THE FINAL ORDER IS UPLOADED ON THE WEBSITE OF ITAT 21 .1 2 .2020 DATE ON WHI CH THE FILE GOES TO THE BENCH CLERK 21 .1 2 .2020 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 PAGE | 7