Income Tax Appellate Tribunal - Ahmedabad
Dhanlaxmi Credit Co.Opreative Society ... vs The Income Tax Officer,Ward-2,, Patan on 24 January, 2017
IN THE INCOME TAX APPELLATE TRIBUNAL
AHMEDABAD ''SMC " BENCH - AHMEDABAD
Before Shri S. S. Godara, JM & Shri Manish Borad, AM.
ITA No.2426/Ahd/2013
Asst. Year: 2009-10
Dhanlaxmi Credit Co-op. Vs. ITO, Ward-2, (Patan).
Society Ltd.,
Poonam Complex, Unjha,
Dist. Mehsana.
Appellant Respondent
PAN AAATD 4278-K
Appellant by Shri D. K. Parikh, AR
Respondent by Shri P. S. Chaudhary, Sr.DR
Date of hearing: 16/01/2017
Date of pronouncement: 24/01/2017
ORDER
PER Manish Borad, Accountant Member.
This appeal of assessee for Asst. Year 2009-10 is directed against the order of ld. CIT(A), Gandhinagar, Ahmedabad, dated 8/8/2013 vide appeal No.CIT(A)/GNR/306/2011-12 arising out of order u/s 143(3) of the Income-tax Act, 1961 (in short the Act) framed on 23.12.2011 by ITO, Ward-2, Patan. Assessee has raised following grounds of appeal :-
1. The Assessing Officer has erred in facts and in law, in making addition Whole Profit of Amt. of Rs. 14,72,940/- and was disallowed and also not granted benefit of Section U/s. 80-P of I. T. Act. But Learned Commissioner of Income Tax (Appeals) Gandhinagar has ITA No. 2426/Ahd/2013 2 Asst. Year 2009-10 granted relief of Rs. 6,17,0867-, Out of Total Fixed Deposits Interest earned Amt. of Rs. 13,85,849/-.
2. That the appellant craves leave to add, to alter, to amend, to modify, to Substitute, delete and/or rescind all or any of the GROUNDS OF APPEALS on or before the final hearing, if necessary so arises. .
2. Briefly stated facts of the case are that assessee is a Credit Co-op. Society Ltd. It filed its return of income on 13.10.2010 declaring NIL income. Case was selected for scrutiny assessment through CASS and notice u/s 143(2) of the Act dated 24.08.2011 followed by notice u/s 142(1) of the Act dated 15.02.2013 was issued along with questionnaire. Necessary details as called for were duly furnished by the Authorized Representative of the assessee. Ld. Assessing Officer while examining the claim of deduction u/s 80P(2)(a)(i) of the Act framed a view that assessee is a primary credit society and not a primary agricultural society and therefore, is out of the ambit of provisions of section 80P(2)(a)(i) of the Act and falls under the provisions of section 80P(4) of the Act and accordingly denied the deduction u/s 80P(2)(a)(i) of the Act. Further during the course of examination of interest income earned on short term deposits and bank securities, ld. Assessing Officer treated it as income from other sources. Ld. Assessing Officer, however, allowed deduction towards expenses of Rs.2,52,607/- incurred for earning interest from bank and taxed the interest income u/s 56 of the Act at Rs.5,32,918/-. However, ld. Assessing Officer denied deduction u/s 80P(2)(a)(i) of the Act and income was assessed at Rs.15,85,740/- and no separate addition towards interest income was made.
ITA No. 2426/Ahd/2013 3Asst. Year 2009-10
3. Aggrieved, assessee went in appeal before ld. CIT(A) and got part relief as ld. CIT(A) observed that assessee is entitled to the benefit of deduction u/s 80P(2)(a)(i) of the Act by following the order of his predecessor. As regards treating of interest income taxable u/s 56 of the Act, ld. CIT(A) held that interest income of Rs.8,55,854/- being the total of interest from deposit on nationalized bank of Rs.7,35,277/-, interest from scheduled bank at Rs.1,08,852/- and Rs.11,725/- as TDS fall under the head income from other sources u/s 56 of the Act and do not qualify for deduction u/s 80P(2)(a)(i) of the Act by observing as under :-
5.2 I have gone through the facts of the case, assessment order, and the submission made by the appellant. Similar disallowance was made in the assessment year 2008-09 by the AO and the appellant had objected the matter before the CIT(A). The CIT(A) vide order No.CIT(A)/GNR/186/2010-11 dated 9/07/2012 held as under;
"I have gone through the facts of the case, the assessment order :7and the submissions, As per the definition of banking as per sec 5(b) of Banking Regulation Act, "Banking" means the accepting for the purpose of lending or investment, of deposits of money from the public, repayable on demand or otherwise, and withdrawal by cheque, draft, order or otherwise. The definition is basic law to be considered to decide whether a credit society is a co-operative bank or not. Only, those credit societies which are allowed to take deposits of money from the public and do other banking activities as defined in the sec 5(b) of Banking Regulation Act would quality to be a co-operative bank. I agree that taking deposits from public cannot be equivalent to taking deposits from members of the society only which has got a much restricted meaning and the relationship between a society and a public has to be understood in a much larger sense, This has been made clear by the Hon'ble jurisdictionat High Court in the case of Baroda Peoples Co-op. Bank Ltd (Supra).
To understand the issue better, I went through the RBI website and found that it has been explained in a report of a high level committee appointed by the Reserve Bank of India in May 1999 under the Chairmanship of Shri K. Madhava Rao, Ex-Chief Secretary, Government of Andhra Pradesh to review the performance of Urban Cooperative Banks (UCBs) and suggest necessary measures to strengthen this sector. The report was published on 14/01/2000 and in para, 7.1 & 7.2 of the report, the following has been narrated:ITA No. 2426/Ahd/2013 4
Asst. Year 2009-10 "7.1 Cooperative credit structure in India is characterized by a plethora of institutional segments. Leaving aside the agricultural cooperative credit institutions, in the urban cooperative credit fold itself, there are 3 types of institutions recognized' by the Banking Regulation Act 1949 (As Applicable to Cooperative Societies). As discussed elsewhere in the Report, these are
(i) primary credit societies/ who virtually function like banks, but whose net worth is less than Rs.l lakh; who are not members of the payment system and to whom deposit insurance is not extended,
(ii) primary cooperative banks, popularly called Urban Cooperative Banks, whose net worth is Rs.l lakh and above; who are recognized as banks, are members of payment system and who enjoy deposit insurance
(iii) cooperative credit societies, who confine their activities to their members alone and who do not perform banking functions. In this chapter, the Committee deals with these cooperative credit societies.
7.2 Under the provisions of Section 5(ccii) of Banking Regulation Act, 1949 (AACS), a cooperative credit society is defined as a cooperative society, "the primary object of which is to provide financial accommodation to its members and includes a cooperative land mortgage bank." This type gf institutions are thrift societies. The distinction between a primary credit society and a cooperative credit society is with reference to their nature of business. The primary object or principal business of a primary credit society is the transaction of banking business, When its paid up capital and reserves attain the level of Rs.l lakh, a primary credit society automatically becomes a primary cooperative bank. However, even after a primary credit society becomes a cooperative bank, it has to apply to RBI for a license to carry on banking business. But it can carry on banking business until it is granted a license or notified that a license cannot be granted to it.
The above report clearly defines the circumstances in which a credit society can be allowed to carry on banking business, These are 'Primary Credit Society', which can carry on business of banking until it is granted a license or notified that a license cannot be granted to it. These credit societies would not get the benefit of the deduction u/s 80P(2)(a)(i).
Considering the above facts, it is dear that the appellant is not allowed to do banking business as defined under Banking Regulation Act and therefore, is not a cooperative bank. Therefore, it is not excluded from the benefit of deduction u/s 80P(2)(a)(i) of the IT Act as it does not fall under the exceptions as provided u/s 8QP(4). I have also noted the decision of honorable TTAT Mumbai bench in the case of Salgaon Sanmitra Sahakari Pathped Ltd. 12 taxmann.corn 246; where both the CIT (Appeals) and the ITAT have held that the corporative credit society in that case was not a cooperative bank , I also respectfully agree with the decision of the ITAT Bangalore "B" Bench in the case of ACIT Vs M/s. Bangalore Commercial Transport Credit Co-operative Society Ltd in ITA No.l069/Bang/2010 for AY 2007-08 dated 08/04/2011 which has decided the issue in favour of the appellant.
Therefore, it is held that the appellant is entitled to the benefit of deduction u/s 80P(2)(a)(i) of the IT Act.
5,1 However, not the entire income is exempted; and it is to be examined whether there was any other interest income on the short term bank deposits and securities included in the total income of this society which has been claimed by them as exempt. The issue ITA No. 2426/Ahd/2013 5 Asst. Year 2009-10 was decided by the Hon'ble Supreme Court in the case of Totgars Co-op. Sale Society Ltd Vs ITO, Karnataka, In the aforementioned judgement, the issue for determination was whether interest income on the short term bank deposits and securities would be qualified as business income u/s. 80P(2)(a)(i) of the IT Act, 1961. The Hon'ble Supreme Court had decided the issue . as under:
"At the outset an important circumstance needs to be highlighted. In the present case, the interest held not eligible for deduction u/s. 80P(2)(a)(i) of the Income tax Act is not the interest received from the members for providing the credit facilities to them. What is sought to be taxed u/s, s 36 of the Act is the interest income arising on the surplus invested in short term deposits and securities which surplus was not required for business purpose. Assessee markets the produce of its members whose sale proceeds at times were retained by it. In this case, we are concerned with the tax treatment of such amount. Since the fund created by such retention was not required immediately for business purposes, it was invested in specified securities. The question before us, is whether interest on such deposits/securities which strictly speaking accrues to the members account could be taxed as business income under section 28 of the Act.
An important point.needs to be mentioned. The words the whole of the amount of profits and gains of business emphasis that the income in respect of which deduction is sought must constitute the operational income and not the other income which accrues to the Society. In the particular case, the evidence shows that the assessee society earns interest on funds which are not required for business purposes at the given point of time. Therefore, on the facts and circumstances of this case, in our view, such interest income falls in the category of 'Other Income' which has been rightly taxed by the Department under section 56 of the I. T. Act"
In the light of the above, the interest income if any, earned from keeping the surplus fund in banks would be taxable u/s 56 and will not qualify for deduction u/s SOP. It is seen that the total interest earned from deposits with other banks' (other than co-op, societies, which is exempt) FD etc is Rs.10,44,394/-. The appellant has mixed funds wherein the members' interest free contribution and accumulated profits are mixed with interest bearing funds. The interest earned from members etc., is Rs, 41,14,0027-and total interest paid is Rs.29,79;405/-. Therefore, for earning total interest of Rs.51,58,396/- the appellant has spent Rs.29,79,405/-, Taking on pro-rata basis, the interest expenses on earning the interest from bank taxable u/s 56 would be Rs. 6,03,224/-( 10,44,394 x 29,79,405/ 51,58,396). Therefore, the interest income which is taxable u/s 56 and is not exempt would be Rs.4,41,170/- (Rs. 10,44,394- Rs. 6,03,224/-). The ground of appeal is decided accordingly."
The facts of the case during the year under consideration are substantially same as in earlier year where addition was made disallowing deduction u/s. SOP of the Act. The addition made by the AO has been deleted without allowing interest income taxable u/s. 56 of the Act. In view of the contentions of appellant and above discussion, and relying on the order of my predecessor for AY 2008-09, it is held that the appellant is to the benefit of deduction u/s 80P(2)(a)(i) of the IT Act.
However, the interest income if any, earned from keeping the surplus in banks would be taxable u/s 56 and will not qualify for deduction u/s 80P of the Act. The issue was decided by the Hon'ble Supreme Court in the case of Totgars Co-op. Sale Society Ltd Vs ITO, Karnataka-(2010) 188 TAXMAN 0282. In the aforementioned judgement, the issue for determination was whether interest income on the short term bank deposits and securities would be qualified as business income u/s.80P(2)(a)(i) of the IT Act, 1961. The Hon'ble Supreme Court had decided the issue as under;
ITA No. 2426/Ahd/2013 6Asst. Year 2009-10 "At the outset an important circumstance needs to be highlighted. In the present case, the interest held not eligible for deduction u/s. 80P(2)(a)(i) of the Income tax Act is not the interest received from the members for providing the credit facilities to them. What is sought to be taxed u/s. s 36 of the Act is the interest income arising on the surplus invested in short term deposits and securities which surplus was not required for business purpose. Assessee markets the produce of its members whose sale proceeds at times were retained by it. In this case, we are concerned with the tax treatment of such amount. Since the fund created by such retention was not required immediately for business purposes, it was invested in specified securities.
The question before us, is whether interest on such deposits/securities which strictly speaking accrues to the members account could be taxed as business income under section 28 of the Act.
An important point needs to be mentioned. The words the whole of the amount of profits and gains of business emphasis that the income in respect of which deduction is sought must constitute the operational income and not the •other income which accrues to the Society. In the particular case, the evidence shows that the assessee society earns interest on funds which are not required for business purposes at the given point of time. Therefore, on the facts and circumstances of this case, in our view, such interest income falls in the category of 'Other Income' which has been rightly taxed by the Department under section 56 of the I. T. Act"
In the light of the above, the interest income earned from keeping the surplus fund in banks or other investments would be taxable u/s 56 and will not qualify for deduction u/s 80P. As per the interest calculation submitted by the appellant, it has earned interest from deposits in nationalized bank an amount of Rs.7,35,277/-, Schedule Banks Rs.1,08,852/-and Rs.11,725/- as TDS. These earnings are part of surplus funds of interest account which comes under the purview of section 56. Thus, as per the provisions of section 56, the total amount of Rs.8,55,854/- is taxable in the hands of the appellant and will not qualify for deduction u/s SOP.
4. Aggrieved, assessee is now in appeal before the Tribunal; whereas Revenue has not filed any appeal against the order of ld. CIT(A).
5. At the outset ld. AR submitted that the only grievance through this appeal is against the order of ld. CIT(A) denying deduction u/s ITA No. 2426/Ahd/2013 7 Asst. Year 2009-10 80P(2)(a)(i) of the Act for the interest income of Rs.8,55,854/- earned from nationalized bank, scheduled bank and TDS on interest i.e. interest income other than derived from investments with any other co-operative society. Ld. AR appraised the Bench by referring to the judgment of Hon. Jurisdictional High Court in the case of SBI vs. CIT
- (2016) 389 ITR 578 (Guj) dated 25th April, 2016 wherein Hon. High Court has held that in case of credit co-operative societies interest income from deposits with nationalized bank/scheduled bank are taxable under section 56 as income from other sources and deduction u/s 80P(2)(a)(i) of the Act cannot be claimed on such interest income. Ld. AR further conceded to this effect that on account of judgment of Jurisdictional High Court in the above referred case assessee is not entitled for deduction u/s 80P(2)(a)(i) of the Act on the interest income of Rs.8,55,854/-, however, assessee should be allowed pro-rata expenses for earning interest income as well as basic statutory deduction of Rs.50,000/- as per provisions of section 80P(2)(a)(i) of the Act which has not been allowed to the assessee. In support of this contention ld. AR referred and relied on the decision of the Tribunal in the case of Kherava Co-op. Credit Society Ltd. vs. ITO, Ward-4, Mehsana in ITA No.2704/Ahd/2015 for Asst. Year 2012- 13 vide order dated 11/02/2016.
6. Ld. DR raised no objection to the contentions of ld. AR to the extent that assessee will not be entitled for deduction u/s 80P(2)(a)(i) of the Act towards interest income of Rs.8,55,854/-, in pro-rata expenses for earning interest income as well as statutory deduction u/s 80P(2)(a)(i) of the Act.ITA No. 2426/Ahd/2013 8
Asst. Year 2009-10
7. We have heard rival contentions and perused the material placed on record and gone through the judgment and decision quoted by ld. AR. After going through the grounds and the submissions made by ld. AR and after considering the issue in the light of ratio laid down in the judgment of Hon. Jurisdictional High Court in the case of SBI vs. CIT (supra), the grievance remains to be adjudicated is towards allowing of pro rata expenses for earning interest income of Rs.8,55,854/- earned from deposits with nationalized/scheduled banks and also allowing statutory deduction of Rs.50,000/- u/s 80P(2)(c) of the Act.
8. We observe that during the course of assessment proceedings ld. Assessing Officer denied the claim u/s 80P(2)(a)(i) of the Act and also observed that income from interest on deposit other than those held with Co-op. Society are liable to be taxed as income from other sources u/s 56 of the Act. Thereafter when the matter was carried before ld. CIT(A) assessee's appeal was partly allowed to the effect that assessee was held to be eligible for claiming deduction u/s 80P(2)(a)(i) of the Act, but interest earned from deposits with scheduled/nationalized banks was held to be taxable u/s 56 of the Act. Assessee came up in appeal before the Tribunal against the action of ld. CIT(A) denying deduction u/s 80P(2)(a)(i) of the Act on the interest of Rs.8,55,854/-.
9. Thereafter in due course of time Hon. Jurisdictional High Court in the case of SBI vs. CIT (supra) decided the issue in the case ITA No. 2426/Ahd/2013 9 Asst. Year 2009-10 of credit co-operatie society about treatment of interest income from deposits of surplus funds in bank to be taxed u/s 56 of the Act as income from other sources. Hon. Court while deciding so observed as follows :-
Held, dismissing-the appeals, (i) that the assessee had claimed deduction under section 80P and not specifically under section 80P(2)(a)(i). The asses- see had also not shown any bifurcation of the income derived from providing credit facilities to its members and the interest earned by depositing surplus funds with the bank. In response to the notice under section 263, the assessee had contended that the reason for treating the interest income received from deposits as business income was that the funds of the business were kept in interest earning account with facility to withdraw the fund as and when necessary to earn interest for and on behalf of its members and that it was one of its activities as provided in section 80P(2)(a) and that the gains of business attributable to such activity were exempted from taxable income. The contention of the assessee that the Commissioner had not held that the interest derived from the deposits in the bank was income from other sources did not merit consideration for the reason that it was for the Assessing Officer, pursuant to the order under section 263 to examine the nature of the income and tax it accordingly. Having regard to the stand adopted by the assessee in response to the notice under section 263, it could not be said that the Commissioner had travelled beyond the scope of the notice under section 263, inasmuch as, he had only dealt with the contention raised by the assessee. The Appellate Tribunal was justified in upholding the invocation of powers under section 263 of the Act by the Commissioner and that the order did not suffer from any legal infirmity.ITA No. 2426/Ahd/2013 10
Asst. Year 2009-10
(ii) That the assessee did not carry on any banking business and its objects did not contemplate investment of surplus funds received from its members.
The business of a credit society like that of the assessee was limited to providing credit to its members and the income that was earned by provid- ing such credit facilities to its members was deductible under section 80P(2)(a)(i). The character of interest was different from the income attributable to the business of the assessee-society providing credit facilities to its members. The interest income derived from investing surplus funds with the bank must be closely linked with the business of providing credit facilities for it to be held attributable to the business of the assessee. Therefore, the profits and gains could be said to be directly attributable to the business of providing credit facilities to its members if there was a direct and proximate connection between the profits and gains and the business of the assessee. There was no obligation on the assessee to invest its surplus funds with the bank. Investing surplus funds in a bank was no part of the business of the assessee providing credit facilities to its members and hence it could not be said that the interest derived from depositing its surplus funds with the bank was profits and gains of business attributable to the activities of the assessee. It was only the interest income derived from the credit provided to its members which was deductible under section 80P(2)(a)(i) and the interest income derived by depositing the surplus funds with the bank not being attributable to the business carried on by the assessee could not be deducted under section 80P(2)(a)(i). There was no infirmity in the orders of the Appellate Tribunal warranting interference.
10. We further observe that during the course of hearing hefore us, ld. AR accepted that assessee is not eligible to claim deduction u/s ITA No. 2426/Ahd/2013 11 Asst. Year 2009-10 80P(2)(a)(i) of the Act on the interest earned on surplus deposits/investments held with Scheduled/Nationalized bank but urged for allowing deduction on pro rata expenses incurred for earning the interest income and also for allowing statutory deduction of Rs.50,000/- u/s 80P(2)(c)(ii) of the Act. Ld. AR also submitted that a total expenses incurred for the year stood at Rs.28,60,298/- and pro rata expenses for earning interest income of Rs.8,55,854/- as against total interest income of Rs.42,39,515/- will be calculated at Rs.5,77,423/-.
11. We observe that ld. AR has referred to the decision of the Co-ordinate Bench in the case of Kherava Co-op. Credit Society Ltd. vs. ITO, Ward-4, Mehsana in ITA No.2704/Ahd/2015 for Asst. Year 2012-13 wherein similar issue of allowing pro rata expenses and allowing statutory deduction of Rs.50,000/- u/s 80P(2)©(ii) of the Act has been adjudicated by the Co-ordinate Bench by observing as under :-
10. From going through the alternate submissions made by the assessee we find that major portion of interest income is from government securities and are not in the nature of short term deposits. Therefore, the facts of the case are clearly distinguishable from the facts discussed in the case of Totagars Co-op.
Sale Society Ltd. vs. ITO (supra) and that of co-ordinate bench in the case of Jafari Momin Vikas Co-op. Credit Society Ltd. (supra) as well as in the case of Dhanalaxmi Credit Co-op. Society Ltd. vs. ITO (supra). This interest income is on investments not of short term nature except bank interest which too includes interest on Fixed Deposits. In these circumstances, we are of the view that as the assessee suo moto has given a proposition of taxing the interest and commission income on investments to be taxed u/s 56 of the Act and has also shown that proportionate expenses of Rs.3,31,828/- have been incurred to earn the above income and the same has duly been accepted by the assessing authority, so we find it justified that Assessing Officer has rightly taxed the interest income of Rs.2,16,689/- as income from other sources. However, deduction u/s 80P(2)(c) ITA No. 2426/Ahd/2013 12 Asst. Year 2009-10 ought to have been allowed to the assessee as section 80P(2)(c) reads as under
:-
Section 80P(2)(c)
(c) in the case of a co- operative society engaged in activities other than those specified in clause (a) or clause (b) (either independently of, or in addition to, all or any of the activities so specified), so much of its profits and gains attributable to such activities as 1 does not exceed,-
(i) where such co- operative society is a consumers' co- operative society, one hundred thousand rupees; and
(ii) in any other case, fifty thousand rupees.
Explanation.- In this clause," consumers" co- operative society" means a society for the benefit of the consumers;] From going through the above provisions it is very clear that the assessee is eligible for deduction of Rs.50,000/- u/s 80P(2)(a)(i) of the Act and the same should have been allowed by the Assessing authority..
11. Therefore, in view of our above discussion, we quash the order of ld. CIT(A) enhancing the addition and also partly allow the appeal of assessee and accordingly the addition made by Assessing Officer shall be reduced to Rs.1,68,305/- [Rs.2,16,689/- minus Rs.50,000/- deduction u/s 80P(2)(c)].
11. Respectfully following the judgment of Hon. Jurisdictional High Court and examining the facts of the case as also in the light of decision of the Co-ordinate Bench discussed in the above paragraphs, we are of following view :-
(1) Assessee is not eligible for deduction u/s 80P(2)(a)(i) of the Act on the interest income earned from surplus deposits held with Nationalized/Scheduled banks.
(2) Assessee will be eligible to statutory deduction of Rs.50,000/-
u/s 80P(2)©(ii) of the Act.
(3) Assessee will also be eligible to claim pro rata expenses for earning interest income of Rs.8,55,854/- assessee's claim of pro rata expenses of Rs.5,77,423/- against the interest income of Rs.8,55,854/- after due verification by the learned Assessing Officer.
ITA No. 2426/Ahd/2013 13Asst. Year 2009-10 We, therefore, direct the Assessing Officer to verify assessee's claim of pro rata expenses by examining the record to be shown for verification by the assessee. Needless to mention proper opportunity of being heard is to be given to the assessee. We order accordingly. The appeal of the assessee is partly allowed for statistical purposes.
12. In the result, appeal of the assessee is partly allowed for statistical purposes.
Order pronounced in the open Court on 24th January, 2017 Sd/- sd/-
(S. S. Godara) (Manish Borad)
Judicial Member Accountant Member
Dated 24/01/2017
Mahata/-
Copy of the order forwarded to:
1. The Appellant
2. The Respondent
3. The CIT concerned
4. The CIT(A) concerned
5. The DR, ITAT, Ahmedabad
6. Guard File
BY ORDER
Asst. Registrar, ITAT, Ahmedabad
ITA No. 2426/Ahd/2013 14
Asst. Year 2009-10
1. Date of dictation 23/01/2017
2. Date on which the typed draft is placed before the
Dictating Member: 24/01/2017 other Member:
3. Date on which 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 fair order comes back to the Sr. P.S./P.S.:
6. Date on which the file goes to the Bench Clerk: 25/1/17
7. Date on which the file goes to the Head Clerk:
8. The date on which the file goes to the Assistant Registrar for signature on the order:
9. Date of Despatch of the Order: