MUNDRA INTERNATIONAL CONTAINER TERMINAL PRIVATE LIMITED,MUNDRA V. THE DEPUTY COMMISSIONER OF INCOME-TAX, AHMEDABAD

ITA 1241/AHD/2024

AI Insights

The case involves cross-appeals by Mundra International Container Terminal Pvt Ltd and the Revenue against the orders of the Learned Commissioner of Income Tax (Appeals) concerning the Assessment Years 2017-18 and 2018-19. The primary issues revolved around the disallowance under Section 14A related to expenses incurred to earn exempt income, the payment of Dividend Distribution Tax (DDT) at prescribed rates, and the allowance of depreciation on intangible assets and deductions under Section 80IA(4)(i). The Tribunal's decision was influenced by previous rulings and judicial precedents, leading to the dismissal of all appeals.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 793256 (ITAT-AHMEDABAD)
• Duration Of Justice: 1 year(s) 3 month(s) 5 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-09-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: B
• Assessment Year: 2017-2018
• Appeal Filed On: 18-06-2024
• Other Referred Cases: Corrtech Energy Ltd. vs. CIT, ACIT vs. S.K. Patel Family Trust, HSBC Asset Management India Pvt. Ltd. vs. Deputy Director of Income Tax, CIT vs. A.L. Logistic Pvt. Ltd., CIT vs. Chettinad Lignite Transport Services Pvt. Ltd.
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: R. P. RASTOGI; WAY OF GROUND NO. AY; WAY OF GROUND NO. AY
• Assessee Lawyers: S.N. SOPARKAR
• Keywords: Depreciation; Earning of tax free income; Double taxation relief; Rule 8D
• Section: 263; 14A

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA No. 1241/Ahd/2024 (Assessment Year: 2017-18) Mundra International Container Terminal Private Limited, Navinal, New Mundra Port, Post Box No.8, Mundra, Kutch [PAN : AADCA 0917 C] Vs. DCIT, Circle 2(1)(1), Ahmedabad ITA Nos. 1261 & 1268/Ahd/2024 (Assessment Year: 2017-18 & 2018-19) Assistant Commissioner of Income-tax, Circle-2(1)(1), Ahmedabad Vs. Mundra International Container Terminal Private Limited, Navinal, New Mundra Port, Post Box No.8, Mundra, Kutch [PAN : AADCA 0917 C] (Appellant) .. (Respondent) Appellant by : Shri S.N. Soparkar, Sr. Advocate Respondent by: Shri R.P. Rastogi, CIT-DR Date of Hearing 17.09.2025 Date of Pronouncement 24.09.2025 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- ITA Nos. 1241 & 1261/Ahd/2024 are the cross-appeals filed by the Assessee and Revenue against the order dated 23.4.2024 passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (‘Ld. CIT(A)’ in short), under Section 250 of the Income-Tax Act, 1961 (‘the Act’ in short), for the Assessment Year 2017-18 and ITA No.1268/Ahd/2024 is the appeal filed by the Revenue against the order dated 23.4.2024 passed by Ld. CIT(A) relating to Assessment Year 2018-19. Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 2– 2. Since common facts and identical issues are involved in all these appeals, they were heard together and are being disposed of by this consolidated order for the sake of convenience and brevity. ITA No. 1241/Ahd/2024 for AY 2017-18 (by Assessee) 3. The assessee has raised following grounds in its appeal :- “1. The learned CIT(A) erred in confirming the disallowance of Rs. 24,00,000/- under section 14A of the Income Tax Act ('Act') read with Rule 8D of the Income Tax Rules ('Rules) as expenditure incurred to earn exempt income 2. The learned CIT(A) erred in making the disallowance u/s 14A read with Rule 8D of the Act without appreciating the fact that the Appellant had sufficient own funds. 3. The learned CIT(A) erred in confirming the payment of Dividend Distribution Tax ('DDT'), on the dividend declared to the Appellant's non-resident shareholders, at the rate prescribed under section 115-0 of the Act4, instead of payment of DDT at the rate prescribed in the Double Taxation Avoidance Agreement between India and Mauritius. 4. The Assessing Officer be directed to grant the refund of excess DDT paid adopting the rate of tax as prescribed under section 115-0 of the Act in excess of the applicable rate prescribed under the India-Mauritius DTAA.” ITA No. 1261/Ahd/2024 for AY 2017-18 (by Revenue) 4. The Revenue has raised following grounds of appeal :- “1.\"Whether the CIT/A) is justified in law and on facts in deleting the disallowance of depreciation of intangible assets of Rs.2,40,44,534/- when the assessee (lessee) as well as the lessor i.e. Adani Ports and Special Economic Zone Ltd, both have claimed depreciation on the same set of assets?\" 2.\" Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the disallowance of Rs.1,12,86,250/- made u/s 14A of the Act to the extent of administrative expenses enumerated under Rule 8D of the Income tax Rules, 1962?\" 3. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) justified in deleting the disallowance of Rs 3,83,13,75,322/- made u/s 80IA(4)(i) without appreciating the facts of the case\".” Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 3– ITA No. 1268/Ahd/2024 for AY 2018-19 (by Revenue) 5. The only effective ground raised by the Revenue is as follows:- “Whether on the facts and in the circumstance’s of the case and in law, the Ld. CIT(A) is justified in deleting the disallowance of Rs.3,88,83,82,604/- made u/s 80IA (4)(i) without appreciating the facts of the case.” Disallowance u/s 14A – AY 2017-18:- Ground Nos. 1 & 2 of the assessee’s appeal Ground No. 2 of Revenue’s appeal 6. The brief facts of the case on this issue are that the Assessing Officer noted that the assessee earned exempt dividend income of Rs.2,01,88,967/- from mutual funds but made no disallowance of related expenses. With investments of over Rs.53 crore in mutual funds and Rs.70 crore in shares, the Assessing Officer applied Rule 8D(2)(iii) due to lack of specific expense details and disallowed Rs.1,12,86,250/- under Section 14A of the Act, being 1% of the annual average of the monthly average of investments amounting to Rs.1,12,86,25,000/-. On appeal, the Ld. CIT(A) held that the disallowance made by the Assessing Officer of Rs.1,12,86,250/- under Section 14A was excessive and he restricted it to Rs.24,00,000/-, based only on mutual fund investments, granting relief of Rs.88,86,250/-. 6.1 Aggrieved by the order of the Ld. CIT(A), both the assessee and Revenue are in appeal before the Tribunal, i.e. assessee is against the confirmation of disallowance of Rs.24,00,000/- and the Revenue is against deletion of disallowance of 1,12,86,250/- u/s 14A of the Act. 6.2 We have heard both the parties on this issue and perused the material available on record. We find that Ld. CIT(A) rightly restricted the disallowance to Rs.24,00,000/- by observing as under:- 4.1. In the facts of the case, I find that the assessee had earned Exempt Dividend Income u/s. 10(35) of the Act from mutual funds, for a sum of Rs. 2,01,88,967/-. The AO in the assessment order found that there was a fresh investment of Rs.70,00,00,000/- in the shares of Container Rail Road Services Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 4– Pvt. Ltd. and the total investment in mutual fund was made for Rs. 53,16,20,000/-. The AO further held that, as per the Tax Audit Report, the assessee has not suo moto disallowed any expenditure on account of interest or on account of corresponding administrative expenditure towards earning of the exempt dividend income of Rs. 2.02 Cr. Relying on the Circular of the CBDT, bearing No. 5 of 2014, dated 11/02/2014, the AO held that expenses which are relatable to earning of exempt income have to be considered for disallowance in spite of the fact, whether any such income has been earned on the investment made during the FY or not. The Rule 8D of the Income Tax Rules, 1962 proposes that, when direct quantification of such expenditure relatable to investments, out of which exempt income is earned, is not ascertainable, a sum of 1 per cent of the annual average of the monthly averages of investments held by the assessee may be taken for the amount of disallowance u/s. 14A. Applying such Rule, the AO has found that the annual average of monthly averages of investment stood at Rs. 1,12,86,25,000/- and therefore, he disallowed the sum of Rs. 1,12,86,250/-, towards the disallowance. 4.2. The assessee during the appeal submitted plethora of decisions in its favour, claiming that the general rule in such decisions states that, if the investments are made out of accumulated free reserves of the assessee, Sec. 14A should not be invoked. One of such decision is in the case of assessee, itself, in the combined decision of the ITAT, Ahmedabad, B-Bench for AY 2011-12 to 2013-14, where the Hon'ble Tribunal held that the Hon'ble Gujarat High Court in the case of Corrtech Energy Ltd. reported in 372 ITR 97 (Gujarat) has held that, where the assessee has not claimed any exempt income, no disallowance u/s. 14A can be made. 4.3. In the present case, I find that the assertion of the AO that a sum of Rs.70,00,00,000/- was invested by the assessee in the shares of M/s. Container Rail Road Services Pvt. Ltd. is factually incorrect, as the investment was not made during the year. It is also found that no exempt dividend income have been received by the assessee company on the shares it held during the year. 4.4. However, the entire exempt dividend was earned on mutual fund units. The aggregate investment in mutual fund units was for Rs. 53,16,20,000/- during the year. The assessee claimed to have free reserves of Rs. 278.52 Crs. It is also submitted by the assessee that the peak amount of investment in mutual fund was Rs.24,00,00,000/- during the year, although the opening as well as closing balance of mutual fund units at the opening and end of FY were NIL. 4.5. In terms of the Departmental Circular of 5/2004, dated 11/02/2014 and following the provision of Sec. 14A, as amended by insertion of an Explanation which states that provision of Sec. 14A shall apply and shall be deemed to have Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 5– always applied in a case, even if no exempt income has accrued or arisen or has not been received during the Previous Year but expenditure has been incurred during the said Previous Year, in relation to such income. 4.6. In light of the above provisions, I find that the disallowance proposed by the Assessing Officer to be correct on principle. However, in terms of the Rule of Hon'ble ITAT, Ahmedabad, B-Bench, in assessee's own case, the quantum of disallowance should not include the sum of investment held in shares of other companies from where no dividend income has been earned. Therefore, the 1 per cent of annual average of monthly averages of investment held in mutual funds may be considered for the disallowance and therefore, the disallowance is restricted to 1 per cent of Rs.24,00,00,000/- (the book value of investments in mutual funds) which is Rs.24,00,000/-. Therefore, assessee gets relief for Rs.88,86,250/- and the disallowance of Rs. 24,00,000/- is sustained. The ground is, therefore, partly allowed.” 6.3 We, therefore, find no error in the order of the Ld. CIT(A) in restricting the disallowance to 1% of the book value of investments in mutual funds of Rs. 24,00,00,000/- i.e. Rs.24,00,000/-, for the elaborated discussion made by him in his order. Thus, the grounds raised by the assessee as well as Revenue in this regard are dismissed. Depreciation on Intangible Assets – AY 2017-18 :- Ground No. 1 of the Revenue’s appeal 7. The issue raised by the Department by way of Ground No. 1 for AY 2017-18 relate to disallowing deprecation on intangible assets of Rs.2,40,44,534/-. This issue has already been decided by the Tribunal in assessee’s own case for AYs 2015-16 & 2016-17 in ITA Nos. 1613 & 1916/Ahd/2019, wherein it was held as under:- “13. Third issue is Disallowance of depreciation on the Infra Structure Usage Facility: The Ld. AO made disallowance of the claim of depreciation of Rs.4,27,45,839/- on the \"Infrastructure Usage Facility' on the ground that depreciation is being claimed by the Assessee/Lessee as well as the Lessor/M/s. APSEZ Ltd for the same assets. Ld. Senior Counsel for the assessee submitted that this issue is covered in favour of the assessee in assessee's own case by the Co-ordinate Bench in ITA Nos. 1117, 2171 & 2172/ Ahd/2017 vide order dated 28.06.2019 wherein held as follows: Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 6– 7. We have heard both the sides and perused the material on record. The assessee has claimed depreciation of Rs. 10,13,23,469/- on infrastructure usages facility on written down value of Rs. 405,23,93,877/- treating the same as intangible asset. The assessee company was using infrastructure facility developed by Mundra Port and Special Economic Zone on account of exclusive right has been given to the assessee company to carry out its terminal operation work. It is further noticed that right from the inception of the assessee company for i.e. assessment year 2004-05 till assessment year 2011-12 the same claim of depreciation has been allowed to the assessee company since assessment year 2004-05. The assessee has entered into aforesaid asset into the block of plant and machinery as intangible asset. The assessee has acquired infrastructure usages facility right from Mundra Port Trust to operate its container operation in Mundra area in the F.Y. 2003-04 relevant to assessment year 2004-05. It is noticed that infrastructure usages facility is a sort of license given by Mundra Port to the assessee company to operate its container operation in Mundra Port area. The assessee has got the right to use and maintain services of certain infrastructural facilities as set out in the infrastructure usages agreement. The assessee has been showing this right on the asset side of the balance sheet and claimed the same as intangible asset on which the deprecation was claimed. With the assistance of ld. representatives, we have gone through the various judicial pronouncements referred by the ld. counsel. Co-ordinate Bench of the ITAT vide ITA No. 1253/Ahd/ 2016 in the case of assessee itself pertaining to assessment year 2009-10 while adjudicating the order passed u/s. 263 by the Pr. CIT for disallowing the claim of depreciation on the similar issue has held that claim of the assessee for depreciation on infrastructural facility existed since 2004-05 should not be disturbed after referring a number of judicial pronouncements. In the case of ACIT vs. S.K. Patel Family Trust 33 taxman.com 678, the Hon'ble Gujarat High Court has held that wherein deprecation on certain asset had been allowed in earlier years could not be disallowed merely on the ground that such assets were not put to use during the year under consideration. In the case of HSBC Asset Management India Pvt. Ltd. vs. Deputy Director of Income Tax vide ITA No. 2028/ Mum/ 2019, the ITAT Mumbai has held that the assessing officer cannot dispute the opening WDV of block asset after having allowed the depreciation in the immediately preceding years and does not open to the assessing officer to take different stand. In the light of the judicial findings and the facts reported in the finding of ld. CIT(A), we do not find any Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 7– infirmity in the decision of Id. CIT(A). Accordingly, this ground of appeal of the revenue is dismissed. 14. Ld CIT DR could not contravent the above submissions of the Assessee Counsel and also not placed any decision or stay order or judgement changing the above decision passed by the Co-ordinate Bench of this Tribunal. Therefore, respectfully following the above judicial precedents the Ground No.1 raised by the Revenue is devoid of merits and liable to be dismissed.” 7.1 Following the decision of Co-ordinate Bench of the Tribunal in assessee’s own case (supra), we are inclined to uphold the decision of the Ld. CIT(A) in allowing the depreciation on intangible assets. Accordingly, the ground No.1 of the Revenue’s appeal for AY 2017-18 is dismissed. Disallowance u/s 80IA(4)(i) – AYs 2017-18 & 2018-19 :- Ground No. 3 of the Revenue’s appeal (AY 2017-18) Ground No. 1 of the Revenue’s appeal (AY 2018-19) 8. The issue raised by the Department by way of Ground No. 3 for AY 2017-18 and Ground No.1 for AY 2018-19 relate to the disallowance u/s 80IA(4)(i) of the Act. In this regard, both the parties fairly agreed that the issue in question is covered in favour of the assessee by the decision of the Tribunal in assessee’s own case for AYs 2016-17 in ITA Nos. 1613 & 1916/Ahd/2019, wherein it was held as under:- 11. Second issue is Disallowance u/s. 80IA(4): The assessee claimed deduction of Rs.295,58,08,285/-u/s. 80IA(4) of the I.T. Act for operating and maintaining the infrastructure facility. The AO has disallowed the claim u/s. 801A(4) on the ground that assessee has not satisfied the condition laid down in section 80IA(4)(i)(b) of the Act. Ld CIT[A] after considering various orders passed by the Tribunal and High Courts allowed the issue in favour of the assessee. 11.1. Ld. Senior Counsel for the assessee submitted that this issue is also covered in favour of the assessee by the High Court of Madras in the case of CIT Vs. A.L. Logistic Pvt. Ltd. [374 ITR 601] and CIT -Vs- Chettinad Lignite Transport Services Pvt. Ltd. in TCA No.741,1266 of 2009 and 162 of 2015 dated 06-03-2019 upholding the decision of Hyderabad ITAT in the case of Ocean Sparkle Limited wherein it was held that assessee is eligible for deduction Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 8– u/s.80IA(4) of the Act. Per contra Ld CIT-DR appearing for the Revenue supported the order passed by the AO and requested to up hold the addition. 12. We have given our thoughtful consideration and perused the materials available on record. Ld CIT[A] considered the issue in detail including the Sub- Concession Agreement entered between the parties and held that the Port was developed by Adani Port Special Economic Zone and it was handed over to the assessee company to Operate and Maintain the Container Terminal as per Clause (G) & (H) of the Agreement. The Assessing Officer has denied the claim of without considering the proviso of Section 80IA(4) of the Act. Sub Concession Agreement was in continuation and part of Concession Agreement between GMB and APSEZ, and therefore, in view of decision of Madras High Court in the case of CIT Vs. A.L. Logistic Pvt. Ltd. judgement dated 23-12-2014 reported in 374 ITR 601 and later judgement dated 12-03-2019 of the Hon'ble High Court of Madras in the case of CIT -Vs- Chettinad Lignite Transport Services Pvt. Ltd. reported in 415 ITR 0107 (Mad) wherein it was held as follows: \"... 8. From a reading of the aforesaid Provisos to Section 80IA(4), it is clear that the Legislature intended to extend the said benefit under Section 80IA of the Act to an enterprise involved in (i) developing or; (ii) operating and maintaining or; (iii) developing, operating and maintaining any infrastructure facility. The term \"infrastructure facility\" has been defined in the Explanation and the same includes a toll road, a bridge ora rail system, a highway project, etc. These are, obviously, big infrastructure facilities for which the enterprise in question should enter into a contract with the Central Government or State Government or Local Authority. However, the Proviso intends to extend the benefit of the said deduction under Section 80IA of the Act even to a transferee or a contractor who is approved and recognised by the concerned authority and undertakes the work of the said development of infrastructure facility or only operating or maintaining the same. The Proviso to sub-section (4) stipulates that subject to the fulfillment of conditions, the transferee will be entitled to the said benefit, as if the transfer in question had not taken place. It has been found by the Assessing Authority himself, in the present case, that the present Assessee M/s.Chettinad Lignite Transport Services Private Limited under an Agreement dated 16.04.2002, captioned as Lignite Transport System with M/s.ST-CMS Electric Company Private Limited, had undertaken the work of developing the said railway sidings and was operating and maintaining the same. The only ground on which, the Assessing Authority denied the said benefit was that the Assessee himself did not enter into any such contract with the Railways or with the Central Government. Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 9– 9. The learned Tribunal, however, in our opinion, rightly applied the Proviso to Section 80IA(4) of the Act and held that since the Assessee was recognised as contractor for these railway sidings, which undoubtedly fell under the definition of \"infrastructure facility\", it was entitled to the said benefit under Section 80IA of the Act. The grounds on which the Assessing Authority denied the said benefit to the Assessee ignoring the effect of Provisos to Section 80IA(4), therefore, could not be sustained. The learned Tribunal, in our opinion, has rightly held that the Proviso does not require that there should be a direct agreement between the transferee enterprise and the specified authority for availing the benefit under Section 80IA of the Act. There is no dispute before us that the Assessee was duly recognised as transferee or assignee of the principal contractor M/s.ST-CMS Company Private Limited and was duly so recognised by the Railways to operate and maintain the said railway sidings at Vadalur and Uthangalmangalam Railway Stations. The findings of fact with regard to the said position recorded by the learned Tribunal are, therefore, unassailable and that clearly attracted the first Proviso to Section 80IA(4) of the Act.\" 12.1. Thus the findings arrived by the Ld. CIT [A] following High Court judgements does not require any interference.” 8.1 Following the decision of Co-ordinate Bench of the Tribunal in assessee’s own case (supra), we decline to interfere with the order of the Ld. CIT(A) on this issue. In the result, the grounds raised by the Revenue for AYs 2017-18 and 2018-19 are dismissed. 9. In conclusion, the assessee’s appeal, as well as both appeals filed by the Revenue, stand dismissed. The order is pronounced in the open Court on 24.09.2025. Sd/- Sd/- (SIDDHARTHA NAUTIYAL) (DR. B.R.R. KUMAR) JUDICIAL MEMBER VICE-PRESIDENT Ahmedabad; Dated 24.09.2025 **btk Printed from counselvise.com ITA Nos. 1241, 1261 & 1268/Ahd/2024 Assessee: Mundra International Container Terminal Pvt Ltd Asst. Year : 2017-18 & 2018-19 - 10– आदेश आदेश आदेश आदेश क\u0007 क\u0007 क\u0007 क\u0007 \b त ल प \b त ल प \b त ल प \b त ल प अ\u0010े षत अ\u0010े षत अ\u0010े षत अ\u0010े षत/Copy of the Order forwarded to : 1. अपीलाथ\u0015 / The Appellant 2. \b\u0016यथ\u0015 / The Respondent. 3. संबं\u001bधत आयकर आयु त / Concerned CIT 4. आयकर आयु त(अपील) / The CIT(A)- 5. वभागीय \b त न\u001bध, आयकर अपील$य अ\u001bधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड) फाईल / Guard file. आदेशानुसार आदेशानुसार आदेशानुसार आदेशानुसार/ BY ORDER, True Copy सहायक सहायक सहायक सहायक पंजीकार पंजीकार पंजीकार पंजीकार (Dy./Asstt. Registrar) आयकर आयकर आयकर आयकर अपील$य अपील$य अपील$य अपील$य अ\u001bधकरण अ\u001bधकरण अ\u001bधकरण अ\u001bधकरण, अहमदाबाद अहमदाबाद अहमदाबाद अहमदाबाद / ITAT, Ahmedabad 1. Date of dictation ….words processed by Hon’ble VP on his PC on 23.09.2025 2. Date on which the typed draft is placed before the Dictating Member …...23.09.2025 3. Other Member …..23..09.2025 4. Date on which the approved draft comes to the Sr.P.S./P.S ……..23.09.2025 5. Date on which the fair order is ed before the Dictating Member for pronouncement …...24.09.2025 6. Date on which the fair order comes back to the Sr.P.S./P.S ………24..09.2025 7. Date on which the file goes to the Bench Clerk ….....24..09.2025 8. Date on which the file goes to the Head Clerk…………………………………... 9. The date on which the file goes to the Assistant Registrar for signature on the order 10. Date of Dispatch of the Order…………………………………… Printed from counselvise.com "