SMT. DEVIKABEN SHAILESH CHOKSHI L/H OF LATE SHAILESH RAMANLAL CHOKSHI,AHMEDABAD V. THE JT. CIT, RANGE-1(3), AHMEDABAD

ITA 951/AHD/2024

AI Insights

The case revolves around a penalty imposed on Smt. Devikaben Shailesh Chokshi for accepting a loan in the form of gold, which was argued to be in violation of Section 269SS of the Income Tax Act. The assessee contended that the gold loan did not constitute 'money' and thus fell outside the purview of Section 269SS. The Tribunal examined the definitions and interpretations of 'loan' and 'money' under the Act, along with the circumstances under which the gold was accepted and returned. The Tribunal concluded that the penalty was not applicable as the transaction did not involve 'money' and there was a reasonable cause for the method of loan acceptance.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 474022 (ITAT-AHMEDABAD)
• Duration Of Justice: 5 month(s) 8 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 14-10-2024
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Next Hearing Date: 26-09-2024
• Assessment Year: 2012-2013
• Appeal Filed On: 06-05-2024
• Other Referred Cases: Ajitnath Hi-Tech Builders (P.) Ltd. vs. Income Tax Officer, Sudhir Kumar Rawat vs. Income Tax Officer, Smt. Pushpalatha vs. Income Tax Officer
• Laws Referred To: Income Tax Act
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: R.N. DSOUZA
• Assessee Lawyers: MEHUL K. PATEL
• Keywords: Condonation of delay; Reasonable cause
• Section: 271D; 273B

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER I.T.A. No.951/Ahd/2024 (Assessment Year: 2012-13) Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi), 2220, Manek Chowk, Ahmedabad-380001 Vs. Joint Commissioner of Income Tax, Ahmedabad-Range1(3), Ahmedabad [PAN No.AAWPC0092J] (Appellant) .. (Respondent) Appellant by : Shri Mehul K. Patel, A.R. Respondent by: Shri R. N. Dsouza, CIT DR Date of Hearing 26.09.2024 Date of Pronouncement 14.10.2024 O R D E R PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi, vide order dated 06.02.2024 passed for A.Y. 2012-13. 2. The Assessee has taken the following grounds of appeal:- “1. That on facts, and in law, the learned NFAC has grievously erred in confirming the levy of penalty u/s. 271D of the Act of Rs. 1,30,63,574/-. 2. That on facts and in law, it ought to have been held that there is no violation of provisions of section 269SS of the Act. 3. In the Alternative, and without prejudice to the above grounds of appeal, it ought to have been held that penalty is not validly levied as the appellant was prevented by a reasonable cause in terms of section 273B of the Act. 4. The appellant craves leave to add, alter, amend any ground of appeal.” ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 2– 3. At the outset, we observe that the appeal is time barred by 30 days. The assessee filed an Affidavit for condonation of delay vide Affidavit dated 03.05.2024, wherein the assessee stated that the order of NFAC was served on her husband’s email address [e-mail] and no physical order was served to the assessee. The assessee’s wife was not conversant with the income tax matters and she does not operate computer. In the last week of April, 2024 the son of the assessee operated the mail id of her late husband and he found out about this order. There was an inadvertent delay in consult with the Advocate of the assessee, as a result of which there was a delay of 30 days in filing of the present appeal. The Counsel for the assessee submitted that there was no mala fide in delaying the filing of the appeal and hence the same may be kindly condoned. 4. Looking into the instant facts and the reasons cited by the assessee for the delay of 30 days in the filing of the present appeal, in the interest of justice, the delay in filing of the present appeal is hereby condoned. 5. The brief facts of the case are that the assessee operates two businesses, M/s. Sparkle Gold and M/s. Saumil Corporation and specializes in trading gold bullion, gold jewelry, and other valuable items. The central issue revolves around a penalty order emanating from a transaction in which the appellant accepted a loan exceeding Rs. 20,000/-, specifically in the form of 5,949.920 grams of gold metal, from Shri Kaushik Kantilal Mandaliya. The agreed rate for this gold was Rs. 2,195.59/- per gram, and the assessee was to pay a yearly license fee of Rs. 120/- per gram to Shri Mandaliya. This transaction was recorded solely through a journal entry in ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 3– the assessee's books, classifying the gold as an unsecured loan. Subsequently, the gold's value, amounting to Rs. 1,30,63,574/-, was reported as capital in M/s. Sparkle Gold. However, the agreement signed on July 12, 2011, indicated that the terms of the loan, particularly the payment of the license fee, violated Section 269SS of the Income Tax Act. The assessee defended his actions before the Assessing Officer by explaining that this was his first year in the retail and wholesale jewelry business and he required gold stock for starting his operations and thus borrowed gold from Shri Mandaliya under the condition of returning it after a specified period. The assessee argued that since he received physical gold rather than cash, the transaction did not contravene the definition of “loan” under Section 269SS of the Act. During penalty proceedings, the Joint Commissioner of Income Tax (JCIT) found that the assessee failed to provide adequate justification for accepting the gold loan in violation of Section 269SS. The JCIT noted that the appellant had not shown any necessary business reason for this form of loan, and for gave reference of various case law cited by the appellant, indicating it did not pertain to the specifics of the case at hand. As per the Assessing Officer, according to the agreement between the assessee and Shri Mandaliya, the transaction was characterized as a loan of physical gold and involved obligations such as license fees, reinforcing the JCIT's stance that this arrangement breached the legal requirements of Section 269SS. Therefore, the JCIT concluded that the circumstances warranted a penalty under Section 271D, and held that the appellant's acceptance of the gold loan without a reasonable cause constituted a violation of the provisions outlined in section 269SS of the ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 4– Act. While passing the order, the Assessing Officer made the following observations: “8. The assessee's contention has been considered but not found acceptable. The assessee has failed to submit any proof as to what was the necessity of the business which warranted acceptance of loans / deposits in the form of gold in violation of section 269SS of the Act. The case laws on which the assessee relied upon is not applicable to the facts of the present case. Further, it is not the case of assessee that the loans / deposits were accepted from such persons who did not have any bank account. Even other-wise also non-maintenance of bank account cannot be considered as reasonable cause for accepting deposits in violation of section 269SS other-wise the entire purpose of bringing the provision of section 269SS on the statute will be defeated. 9. In view of the above facts and the document/details available as per records, it shows that \"As per agreement dated 12/07/2011 between assessee and Shri Kaushik Kantilal Mandaliya, Il was decided that Shri Kaushik Kantlial Mandaliya will give the gold 5949.920 grams as loan to the assessee @ rate of Rs.2195.59 and us such the assessee will pay license fee rate Rs. 120/- per gram per annum an gold to Shri Kaushik Kantilal Mandaliya. As per the statement recorded of Shri Kausnik Kantilal Mandallya, the transaction was made only by passing journal entry The assessee treated the gold as loan and shown in his personal books of account by passing entry as unsecured loan. Thereafter, the loan amount of Rs.1,30.63.574/- was Introduced as capital in proprietary business le. In M/s Sparkle Gold. As per section 269SS of the Act \"no person shall, after the 30th day of June, 1984, take or accept from any other person (hereafter in this section referred to as the deposition any loan or deposit otherwise than by an account payee cheque or account payee bank draft exceeding Rs. 20,000/-\". Therefore, the loan acceptable in form of Gold is violating the provision of section 269SS of the Act. Therefore, I am of the opinion that this is a fit case for levy of penalty u/s. 271D of the Act as the assessee has violated the provisions of section 269SS without any reasonable cause in accepting the loans/deposits in the form of Gold amounting to Rs.1,30,63,574/- from Shri Kaushik Kantilal Mandaliya during the year under consideration. 11. Accordingly, I hereby levy a penalty of Rs.1,30,63,574/- u/s 271D of the Act, for accepting loans/deposits otherwise than by account payee cheque/draft in violation of section 269SS of the Act. 12. Assessing Officer is directed to issue demand notice and challan accordingly and make necessary entries in the records.” ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 5– 6. In appeal Ld. CIT(Appeals) confirmed the penalty imposed by the Assessing Officer. Ld. CIT(Appeals) observed that two primary issues emerge for consideration in the appeal filed by the assessee. The first pertains to the assessee's claim that this was the inaugural year of his business in retail and wholesale gold jewellery, necessitating a loan of physical gold from Shri Kaushik Kantilal Mandaliya. The assessee submitted a Gold Agreement during penalty proceedings to support this claim and contended that the JCIT erred in holding that no evidence was provided to justify the acceptance of loans outside the prescribed methods outlined in Section 269SS of the Income Tax Act. The second issue raised by the assessee was around the interpretation of the term \"money\" in the context of Section 269SS of the Act. The assessee submitted before Ld. CIT(Appeals) that the physical gold accepted as a loan does not qualify as \"money\" and relied on the judgment from the Allahabad High Court, which held that bullion and metal should not be included in the legal or popular definitions of “money”. After thorough deliberation, Ld. CIT(Appeals) held that the assessee has not successfully substantiated his claims regarding the necessity of accepting loans in physical gold. Ld. CIT(Appeals) observed that the JCIT concluded that the appellant failed to provide adequate proof of business necessity justifying the acceptance of loans in a manner contrary to the methods specified in Section 269SS of the Act, which prohibits the acceptance of loans exceeding Rs. 20,000 in any form other than through an account payee cheque, bank draft, or specified electronic means. Ld. CIT(Appeals) held that the assessee's submission that gold metal in physical form does not constitute \"money\" conflicts with his own position that he ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 6– accepted this gold as a “loan”. This inconsistency highlights a significant violation of Section 269SS of the Act, which explicitly excludes precious metals as acceptable forms of loan acceptance. The penalty under Section 271D was levied due to this clear contravention. Despite the assessee's claims regarding the initial stage of his business and the need for flexibility in loan acceptance, the JCIT correctly noted that the evidence provided, including the Gold Agreement, did not sufficiently demonstrate any reasonable cause for the deviations from statutory requirements. Furthermore, Ld. CIT(Appeals) held that the existence of bank accounts for both the assessee and the lender negates the argument that there were no other options for loan acceptance. Therefore, Ld. CIT(Appeals) held that the assessee failed to demonstrate the necessity for the method of loan acceptance he chose, and the arguments presented by the assessee do not justify a deviation from the provisions of the law. Accordingly, Ld. CIT(Appeals) upheld the penalty imposed by the JCIT. While passing the order, Ld. CIT(Appeals) made the following observations: “5.3 The appellant emphasizes that the term \"money\" has a legal meaning as well as a popular sense both of which bar the inclusion of bullion or metal of any kind as such in the concept of \"money\". On the one hand, the appellant himself contends that the gold metal in physical form had been accepted by him in the form of a \"loan\" and on the other hand the appellant raises a plea that \"gold\" in physical form does not fall within the meaning of \"money\". Whether the gold metal or any other valuable item is accepted as and by way of loan or deposit by any person from any other person, it certainly indicates the contravention of the provision of Section 269SS of the Act, which specifically provides for the specified mode of carrying out such transactions. In the event of contravention of such provision of Income-tax Law, it attracts the provision of Section 271D of the Act, which lays down the levy of penalty in such cases. When there is a clear provision of any bar or specified mode of carrying out any transaction enumerated in any of the statutes, whether it be relating to revenue or tax-related law or any other law, the appellant cannot be permitted to take advantage by giving a different meaning or interpretation or connotation or law and raising a plea that the appellant had taken gold in physical form as it was his ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 7– first year of business of gold jewellery - retail and wholesale As stated above the provision of Section 269SS does not include the mode of carrying out such transactions on the form of any precious metal in physical form. Thus, I concur with the view of the JCIT in holding that there was no reasonable cause for accepting the loans from a third party in the mode and manner not specified in Section 269SS of the Act. I also concur with the view of the JCIT that the appellant had tailed to submit any evidence regarding the necessity of the business which warranted acceptance of loans in the form of gold metal in physical form, i.e. otherwise than by way of a mode prescribed specifically in Section 269SS of the Act. I also concur with the view of the JCIT in not accepting the Explanation (i) to Section 269SS of the Act, which is raised as a plea by the appellant that the gold metal accepted as a loan by the appellant does not fall within the meaning of 'money\" and hence it does not attract the provision of Section 269SS of the Act. Whether gold metal or any other precious metal or any other valuable item falls within the definition of money or not, is not the question to be considered here, but the question that arises here is the mode adopted by the appellant for accepting loans for his business purpose is not in accordance with the provision of Section 269SS of the Act. 5.4 It is an undisputed fact that the appellant had admittedly raised loans in the form of gold metal. It is also an undisputed fact that gold metal or any other precious metal is not prescribed as one of the modes of acceptance of loans in Section 269SS of the Act. Hence, it is a clear violation of the provision of Section 269SS of the Act, which entails the levy of penalty u/s 271D of the Act. 5.5 In view of the above discussion, the facts that are involved in the instant case reveal that the appellant bad miserably failed to prove the necessity of using any other mode of raising loans otherwise than by way of the modes enumerated specifically in the provision of Section 269SS of the Act, thereby attracting the levy of penalty under the provision of Section 271D of the Act. Merely because the appellant had placed on record a copy of the Gold Agreement in the course of penalty proceedings before the JCIT, does not prove that there was a reasonable cause in not following the provision of Section 269SS of the Act. Be that as it may, the Statement of Facts and written submission of the appellant are examined in light of the evidences relied upon by him in the course of appellate proceedings. It is undisputed that the impugned amount of Rs. 1,30,63,574/- was accepted as a loan by the appellant from a third party in the form of gold metal in physical form during the financial year 2011-12 relevant to A.Y 2012-13. It is not a case where the appellant or the said third party did not have bank accounts at the relevant time or there was any reasonable cause for not following the provision of Section 269SS of the Act. At the appellate stage, the appellant is trying to twist the facts by raising a plea that it was the first year of the business of retail and wholesale trade in gold jewellery, and hence the appellant adopted such a mode of acceptance of loans. None of the case- laws that are relied upon by the appellant support the appellant's case. 5.6 Thus, taking into account the facts and circumstances of the case and the provisions of law, I do not find any reason to interfere in the action of the JCIT of levying the penalty of Rs. 1,30,63,574/- u/s.271D of the Act for violating the ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 8– provision of Section 269SS of the Act by way of accepting the loans by way of gold metal in physical form. Thus, the grounds of appeal raised in the Memo of Appeal stand dismissed. 6. Thus, to conclude, the appeal stands dismissed.” 7. The assessee is in appeal before us against the aforesaid order passed by the CIT(A) dismissing the appeal of the assessee. 8. Before us, the Counsel for the assessee took several arguments in support of the contention that this is not a fit case for levy of penalty, looking into the language of Section 269SS of the Act and the facts of the assessee’s case. The Counsel for the assessee submitted that Explanation (iii) to Section 269SS of the Act stated that “loan or deposit” means loan or deposit of “money”. Therefore, looking into the definition of loan and deposit, it is evident that the loan or deposit has to be only a loan taken in the form of “money” and the “Gold” loan taken by the assessee falls outside the purview of Section 269SS of the Act, in the first instance. Therefore, since the assessee has taken loan of Gold metal and not money, and since the provisions of Section 269SS of the Act deals with loans or deposits of “money”, as per Explanation (iii) of the said section, there is no violation of provision of Section 269SS of the Act. Secondly, the Counsel for the assessee drew our attention to Clause 32.2 of the Finance Act, 1984, which brought into force the provisions of Section 269SS of the Act, which was “with a view to countering this device, which enables taxpayers to explain away unaccounted cash or unaccounted deposits…”. Accordingly, the Counsel for the assessee submitted that the objective of enacting Section 269SS of the Act was to stop taxpayers from bringing unaccounted cash or ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 9– deposits in their books, however, in assessee’s case, no cash or deposits were involved and both the assessee as well as Mr. Kaushik Mandaliya (the lender) was both have reported all the required details in their respective books of accounts and there is nothing which is unaccounted and therefore, there is neither any evasion of tax nor any intention to evade taxes. The third argument of the Counsel for the assessee was that entry for Gold taken is booked as “unsecured loan” in the journal entry in his books of accounts. Gold was taken with a condition to return the same after a stipulated time and therefore, there was no other way to book an entry in his books of accounts other than journal entry in order to record a transaction in it’s actual form. The Counsel for the assessee relied on judicial precedents in support of the contention that provisions of Section 269SS of the Act were not attracted merely on the basis of journal entries. The Counsel for the assessee further submitted that there was a reasonable cause for taking the Gold from the lender which was that this was the assessee’s first year in jewellery retail and wholesale business and it was with this intention that the assessee took loan of Gold stock to start his business. The concerned Gold bars of 5949.920 grms were part of Mr. Kaushik Mandaliya stock-in- trade held by him in his books of accounts. The assessee also furnished copy of agreement between Mr. Kaushik Mandaliya and himself. Further, Mr. Kaushik Mandaliya (lender) also appeared before the Income Tax Department and has given his statement in response to summons issued to him by the Income Tax Department. Further, the Counsel for the assessee also submitted that in terms of the agreement, assesse returned the Gold metal to Mr. Kaushik Mandaliya on 07.10.2013. The Counsel for the ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 10– assessee submitted that as per the provisions of Section 271D penalty could not be imposed in case of reasonable cause having been adduced by the assessee. In the instant case, the assessee has been able to give adequate documentary evidences as well as reasonable cause, so as to fall outside the purview of provisions of Section 271D of the Act. 9. In response, the Ld. D.R. placed reliance on the observations made by the Assessing Officer and the Ld. CIT(A) in their respective orders. 10. We have heard the rival contentions and perused the material on record. 11. In view of the arguments placed on record before us and the arguments of the Counsel for the assessee which have been reproduced in the precedent part of the judgment, we are of the considered view that this is not a fit for levy of penalty under Section 271D of the Act. This is for the reason that from the facts produced before us, it is evident that there was no intention on part of the assessee to evade payment of taxes or to bring any unaccounted cash outside the books of accounts. The assessee had started a new jewellery business, for which purpose it took a Gold loan from Mr. Kaushik Mandaliya and entered into an agreement for the same. The Gold loan was duly accounted for by the assessee in his books of accounts as his stock-in-trade and further, the assessee had also returned this Gold back to the lender after a stipulated time. The above facts have not been disputed by the Department. Further, we also observe that Explanation (iii) of Section 269SS of the Act states that “loan or deposit” means loan or deposit ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 11– of “money”. Therefore, from the plain language in the Statute itself, the provisions of Section 269SS of the Act are only attracted if the loan or deposit has been taken by the assesseee in the form of “money” and “Gold metal”, by the very definition of loan falls outside the purview of Section 269SS of the Act. Further, we would like to place reliance on some judicial precedents which have thrown useful like on the subject. 12. In the case of Ajitnath Hi-Tech Builders (P.) Ltd. 92 taxmann.com 228 (Bombay), the High Court held that journal entries constitute a recognized mode of recording of transactions and in absence of any adverse finding by authorities that journal entries were made with a view to achieve purposes outside normal business operations or there was any involvement of money, there is a reasonable cause for not complying with section 269SS and penalty under section 271D is not to be imposed. 13. The SLP filed by the Department was dismissed by Hon’ble Supreme Court as reported in 102 taxmann.com 57 (SC). 14. In the case of Sudhir Kumar Rawat 148 taxmann.com 155 (Jabalpur - Trib.), the ITAT held that penalty under Section 271D was levied upon assessee for alleged violation of Section 269SS for having received certain amount from his wife in cash but it was found that assessee had not received any amount in cash from his wife and instead he received sale consideration for a shop owned by his wife and ultimately returned said amount to his wife in cash, penalty as levied was unsustainable in law. ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 12– 15. In the case of Smt. Pushpalatha 165 taxmann.com 767 (Bangalore - Trib.), the ITAT held that where assessee sold a property and received cash exceeding Rs. 20,000/- as part of sale consideration, since amendment effected by Finance Act, 2015, to Section 269SS, which had laid a restriction for receiving cash for transfer of immovable property would not have come to knowledge of assessee who was a woman having elementary education and no knowledge of tax laws, there was reasonable cause as mandated under Section 273B for failure to comply with Section 269SS and, therefore, penalty under Section 271D was not warranted and same was to be deleted. 16. Accordingly, in view of the facts of the assessee’s case and the judicial precedents on the said subject which have held that provisions of Section 271DD of the Act are not attracted in circumstances where the assessee has been able to demonstrate a reasonable cause for non-complying with the provisions of Section 269SS of the Act, no penalty can be levied under Section 271D of the Act, we are of the considered view that Ld. CIT(A) erred in facts and in law in upholding the penalty under Section 271D of the Act on the assessee, looking into the instant facts. 17. In the result, the appeal of the assessee is allowed. This Order pronounced in Open Court on 14/10/2024 Sd/- Sd/- (ANNAPURNA GUPTA) (SIDDHARTHA NAUTIYAL) ACCOUNTANT MEMBER JUDICIAL MEMBER Ahmedabad; Dated 14/10/2024 TANMAY, Sr. PS TRUE COPY ITA No. 951/Ahd/2024 Smt. Devikaben Shailesh Chokshi (L/h. of Late Shailesh Ramanlal Chokshi) vs. JCIT Asst.Year –2012-13 - 13– आदेश की Ůितिलिप अŤेिषत/Copy of the Order forwarded to : 1. अपीलाथŎ / The Appellant 2. ŮȑथŎ / The Respondent. 3. संबंिधत आयकर आयुƅ / Concerned CIT 4. आयकर आयुƅ(अपील) / The CIT(A)- 5. िवभागीय Ůितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाडŊ फाईल / Guard file. आदेशानुसार/ BY ORDER, उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad 1. Date of dictation 01.10.2024(Hon’ble Member made on his dragon software and the remaining part dictated) 2. Date on which the typed draft is placed before the Dictating Member 01.10.2024 3. Other Member………………… 4. Date on which the approved draft comes to the Sr.P.S./P.S 08.10.2024 5. Date on which the fair order is placed before the Dictating Member for pronouncement .10.2024 6. Date on which the fair order comes back to the Sr.P.S./P.S 14.10.2024 7. Date on which the file goes to the Bench Clerk 14.10.2024 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…………………………………… "