Income Tax Appellate Tribunal - Delhi
Nilgiri Cuultivation (P) Ltd, New Delhi vs Assessee on 10 June, 2015
IN THE INCOME TAX APPELLATE TRIBUNAL
(DELHI BENCH ' F', NEW DELHI)
BEFORE SHRI G. C. GUPTA, HON'BLE VICE PRESIDENT
AND SHRI T.S. KAPOOR, ACCOUNTANT MEMBER
I.T.A. No.902 /Del/2009
Assessment year : 2004-05
Nilgiri Cultivations Pvt .Ltd., Vs. DCIT, Circle 13(1),
(now known as DLF Utilities Ltd.) New Delhi
th
DLF Centre, 9 Floor,
Sansad Marg,
New Delhi-110 001
GIR / PAN:
(Appellant) (Respondent)
Appellant by : Shri Pradeep Dinodia, CA
Shri R. K. Kapoor, CA
Respondent by : Shri Dam Kununjna Sr. DR
Date of hearing : 15.05.2015
Date of pronouncement : 10.06.2015
ORDER
PER T.S. KAPOOR, AM:
This is an appeal filed by assessee against the order of Ld. CIT(A) dated 09.01.2009. This appeal was earlier heard on 12.03.2015. However, the appeal was refixed and finally was heard on 15.05.2015. The assessee has taken five grounds of appeal, out of which grounds 1 & 5 are general in nature and do not require adjudication whereas ground No.3 & 4 relate to charging of interest u/s 234B and 234D and withdrawing of interest allowed u/s 244A which the Ld. A.R. had not pressed during the course of 2 ITA No.902/Del/2009 proceedings before us. The only effective ground raised by assessee is contained in ground No.2 which is reproduced below:
"2 That on the facts and in the circumstances of the case and contrary to the provisions of law, the learned Commissioner of Income-tax (Appeals) has erred in confirming the addition of Rs.2, 18,61 ,495/- made by the learned Assessing Officer by disallowing the loss 1 expenditure on account of Stamp Papers purchased for buying Stock of Lana by Companies amalgamated with the Appellant Company but which could not be utilized.
2.1 That the learned Commissioner of Income Tax ( Appeals) has grossly erred in law and on facts of the appellant's case in holding that the expenditure incurred by appellant were on capital account.
2.2 That the learned Commissioner of Income Tax ( Appeals) has grossly erred in law and on facts of the appellant's case in holding that the expenses 1 loss on surrender of stamp papers did not pertain to the year under consideration.
2.3 That the learned Commissioner of Income Tax (Appeals)'s order in confirming the disallowance of claim for surrender of stamp papers is based on surmises, conjectures and imaginative consideration and the same is prayed to be quashed.
2.4 That the order passed by learned Assessing Officer and confirmed by the learned Commissioner of Income Tax (Appeals) is bad in law."
2. The brief facts of the case as noted in the assessment order are that the assessee company is a wholly owned subsidiary of M/s. DLF Universal Ld. and is engage in the business of real estate development. The assessee had filed return of income declaring a loss of Rs.1,06,84,188/-. The case of the assessee was selected for scrutiny. During assessment proceedings, the A.O. observed that the assessee had debited an amount of Rs.2,18,61,495/-being 3 ITA No.902/Del/2009 loss on account of expenditure on stamp papers and therefore, the assessee was show caused as to why the loss of stamp papers should not be disallowed. The assessee submitted that the assessee was engaged in the real estate development business and land purchased from land owners, is reflected in the balance sheet as stock in trade. It was submitted that 19 group companies were merged in the assessee company vide order of Hon'ble High Court and these companies were also engaged in the business of real estate development and these companies had purchased stamp papers for execution of various land purchases from various farmers. However, the sale deeds could not be executed as farmers had refused to execute the same and, therefore, an application for refund on account of these stamp papers was filed before Collector, Gurgaon on 27.04.2001 and Collector Gurgaon vide order dated 08.02.2003 had rejected the claim of these companies on the ground that the claim wass barred by limitation u/s 50 of Indian Stamp Act. It was further submitted that the total amount involved on account of purchase of stamp papers was Rs.2,42,90,550/- out of which Rs.24,29,055/- was written off in Assessment Year 2002-03 itself as the claim of refund was available for only 90% of value stamp papers. The assessee had claimed balance of Rs.2,18,61,495/- as loss in the year under consideration. The A.O. however, did not accept the argument of assessee and made addition of Rs.2,18,61,495/- by holding as under:
"8. I have carefully considered the submissions of assessee on merits and in the facts and circumstance of the case. The same are not acceptable due to following reasons :-
(1) The claimed loss) expenditure cannot be held to be on Revenue account The claimed loss/ expenditure is not allowable either in the AV. 2001·-02 and 2002-03 or in A.Y. 2004-05 as in the facts of the 4 ITA No.902/Del/2009 case assessee clearly failed to prove that this loss/ expenditure was on revenue account 'and not related to investment activity The assessee in its accounts for the A. Y 2003-04 shown this amount as loans and advances and not the part of closing stock The erstwhile 19 companies as well as the assessee company has made investments in agricultural lands in past therefore it cannot be held at the stage of purchase of stamp paper that whether the 19 companies amalgamated in assessee company has purchased these stamp papers for purchasing agricultural land for Investment purposes or trading purposes.
The onus of proving necessary facts in order to avail the deduction under section 37(1) of the I. Tax Act is on the assessee. If, therefore, the assessee fails to establish the facts necessary to support his claim for deduction u/s 37(1) of I. Tax Act, the claim for deduction of expenditure is not admissible as held by Hon'ble Supreme Court in the case of CIT Vs. Calcutta Agency Ltd. (1951) 19 ITR 191. Further, the burden to prove the loss is on the assessee who alleges and the loss cannot be said to be satisfactory proved unless all the particulars with regard to this are clearly shown - CIT Vs. Radha Krishna Ramnath AIR 1929No. 153, CIT Vs. Calcutta Agency Ltd. and Mannalal Ratan lal Vs. CIT (1965) 58 ITR 84 (Cal.).
(IV The claim of loss/ expenditure do not pertains to the assessment year under consideration Without prejudice to the above, these stamp papers were purchased on 22.08.2000 and 01.09.2000 and barred by time limit after 6 months as evident from the order of collector, Gurgaon dated 08.02.2003. Thus, this claim of loss was crystallized in F.Y. 2000-01 itself and thus, pertains to A.Y. 2001-02. Assessee is a investor as well as real estate developer and it cannot be presumed that it was not aware about the Stamp Act. Moreover, the order of Collector, Gurgaon is also dated 08.02.2003, which was received by the assessee on 20.07.2005. Therefore, by no stretch of logic this claim of loss/expenditure is related to assessment year 2004-05. The following table made it clear :-
S.N. Description Date Fin. Assessment
Year Year
1 Purchase of stamp papers 22.08.2000 & 2000-01 2001-02
5 ITA No.902/Del/2009
01.09.2000
2 Execution of stamp papers March, 2001 2000-01 2001-02
3 Time barring limit as per stamp Act March, 2001 2000-01 2001-02
4 Order of collector Gurgaon 08.02.2003 2002-03 2003-04
5 Receipt of order of collector Gurgaon 12.07.2005 2004-05 2005-06
(as per certified copy furnished by the
A.R.)
The assessee was following mercantile system of accounting, therefore, only the income or expenditure that has been arisen/ incurred during the previous year is to be accounted for. Since the assessee has not established that the claimed loss/ expenditure has accrued during the accounting year, therefore, the same is not allowable expenditure/ loss as held in the case of North Arcot District Co-op. Supply & Marketing Society Ltd. Vs. CIT (1987) 165 ITR 623 (Mad.) and Yousuf Sagar Abdulla & Sons P. Ltd Vs. CIT (1990) 185 ITR 371 (Ker.). This principle has duly been affirmed by Hon'ble Supreme Court in the case of Indermanl Jatia Vs. CIT (1959) 35 ITR
298. Therefore, the claim of the assessee for allowance of expenditure/ loss of Rs. 2,18,61,495/- is rejected.
9. Facts of the case suggest that assessee was purchasing these agricultural lands for investments instead of business. The assessee has already failed to prove that this claim of expenditure/ loss was on account of business transaction.
10. In view of the above discussion, the loss on stamp paper of Rs.2,18,61,495/-, claimed by the assessee company as revenue expenditure for the year under consideration is disallowed and added back to it total income. I am satisfied that the assessee has furnished inaccurate particulars of its income and, has deliberately concealed its Income on this issue, therefore, penalty proceedings u/s 271 (1 )(e) have been initiated separately. (Addition of Rs. 2,18,61,495)"
3. Aggrieved, the assessee filed appeal before Ld. CIT(A) and reiterated its arguments. However, Ld. CIT(A) also did not agree with the contention of assessee and upheld the addition made by A.O. by holding as under:6 ITA No.902/Del/2009
"I have examined the submission made by the appellant before me and also the reasoning given by the Assessing Officer in disallowing the claim of appellant of treating the stamp paper purchase as revenue expenditure. It is seen that these stamp papers were purchased during F. Y. 2000-0 I, relevant to A. Y. 2001-02 by nineteen different companies of Rs. 2,42,90,550/-. These different companies were amalgamated with Nilgiri Cultivation Pvt. Ltd., as a result of the order of the Hon'ble Delhi High Court effective from 1.4.1999. It is seen that 10'% of these stamp paper value i.e. Rs.24,29,055/- has been written off in A. Y. 2003-04 and the remaining amount i.e. Rs.2,1 8,61,495/- has been claimed in the assessment under consideration. On going through the balance sheet of 19 different companies, it is seen that those companies were engaged in investments as well as purchase and after development sales of the land. It is not clear from the balance sheet or details filed by the appellant whether the land which was intended to be purchased was part of investment or stock in trade. However, from the fact that expense was debited under the head 'loan and advances' and not under the head 'stock in trade', it is ample clear that the purchase of land was intended for investment purposes. It is also 'seen that the appellant has not filed any documentary evidence or any other supporting evidences to substantiate its claim that these stamp papers were purchased by the erstwhile 19 companies for purchase of land.
It is seen that the expenditure was not incurred by the appellant during the year under reference. The validity of the stamp papers has lapsed in the financial year 2000-01 which was relevant to A Y 2001-
02. If the appellant's contention is to be believed that this expenditure is revenue expenditure then it should have been claimed in the same A.Y. i.e. A.Y. 2001-02 and not in the instant year. Further, it is seen that the appellant has claimed 10% of the stamp paper expenditure i.e. Rs.24,29,055/- in A Y 2003-04 which itself shows that the expenditure was a capital expenditure and not a revenue expenditure as claimed by the appellant during the course of assessment and appellant proceedings. Further, the claim of the appellant that the agreements for purchase of land with the prospective sellers were made by the erstwhile 19 companies was for stock in trade is not supported by the agreements made with the intended sellers.7 ITA No.902/Del/2009
It is also seen that the appellant has filed copies of agreement made with the proposed sellers of land with reference to following companies:-
S. No Name of company Value of stamp
papers
purchased (Rs.)
1. Swastha Builders Pvt. Ltd. 4,87,500
2. Vidhur Cultivations Ltd. I 27,38,645
3. Madhur Cultivation Ltd. 43,04,580
4. Aravali Cultivations Ltd. 42,72,710
For other companies, no agreement with proposed sellers are filed before me even though the appellant was specifically asked for those copies of agreement vide point no.5 of this office letter dated 26.12.2008. In the absence of the copies of agreement, it cannot be accepted that the stamp papers were purchased for the purpose of purchase of land by the remaining 15 companies. Moreover the agreements filed by the appellant in respect of 4 companies are unregistered agreement, written on plain papers having no legal value.
In view of the facts discussed above, the following fact emerges:
1. The appellant fails to establish that the stamp papers were actually purchased by the erstwhile 19 companies for acquiring land for the purpose of stock in trade;
2. The appellant himself has shown the expenditure under head 'loan and advance' and not under the head 'purchase/stock in trade' which shows that the expenditure incurred, if any, was not a revenue expenditure.
3. The appellant has not filed copies of agreement in respect of 15 companies entered into with proposed sellers.8 ITA No.902/Del/2009
4. The agreement filed in respect of four companies is unregistered documents on plain papers which have no legal validity.
5. The appellant itself has claimed 10% of the expenditure in A Y 2003-04 which shows that the expenditure was not revenue expenditure.
In view of the above observations it is abundantly clear that the expenditure on account of stamp paper purchased was not supported by various documents and was not at all revenue expenditure allowable during the year under consideration. The reliance is placed on the judgement of Hon'ble Kerala High Court in the case of CIT Vs. M/s Malabar Building Products Ltd. (2001) 251 ITR 487 wherein it is held that "expenditure incurred by the assessee on stamp paper in connection with registration of units in its names would not be allowable as deduction U!5 37(1) or u/s 57(iii) of the I. T Act".
"The assessee purchased units of units of Unit Trust of 1ndiafrom persons other than Unit Trust of India. It incurred expenditure on purchase of stamp paper for registration of units as deduction in computing income from units. It was held that the said expenditure was not merely for purpose of getting dividend but for registering transfer of units with Unit Trust of India in favour of the assessee. Therefore, said amount was spent in connection with acquisition of units. Hence, the expenditure in question was a capital expenditure.
Expenditure incurred by the assessee on stamp paper in connection with registration of units in its name would not be allowable as deduction u/s 37(1) or u/s 57(iii) a/the Income-tax Act, 1961. "
In view of the aforesaid discussions, I do not find any infirmity in the Order of the A.O. and disallowance made is fully justified. Therefore, this appellant is dismissed."
4. Aggrieved, the assessee has filed appeal before us. At the outset, Ld. A.R. invited our attention to the facts of the case which were contained in 9 ITA No.902/Del/2009 the form of synopsis / facts. Ld. A.R. submitted that assessee was a company engaged in the business of real estate development. He submitted that other group companies of assessee were also engaged in similar business and which got merged with the assessee company w.e.f. 01.04.1999. Ld.A.R. submitted that it was undisputed fact the merging companies of the assessee had purchased stamp papers for registration of land in ordinary course of business for registration of land purchases. However, the stamp papers could not be utilized as sellers had backed out of the agreements and, therefore, stamp papers remained unutilized. It was submitted that only 90% of the cost of stamp papers could have been recovered from revenue authorities, therefore, assessee itself had written off 10% of the cost of stamp papers in the year itself and had made claim with revenue authorities for refund of 90% of the cost of stamp papers. Therefore, the amount for 90% of claim was not written off in the year of purchase as assessee was hopeful of getting refund. Ld.A.R. further submitted that during the year under consideration, the assessee realized this fact that the amount is not recoverable and, therefore, it decided to write off the same. Ld.A.R. submitted that the case of the assessee was squarely covered by the order of Hon'ble Supreme Court in the case of Kerala State Industrial Development Corpn. Ltd. 2012 (TIOL) 83 SCIT, wherein it has been held that the commercial test and business exigency test, need to be applied for suggesting as to whether deduction u/s 36(1)(vii) is allowable or not. It was submitted that in that case, assessee had given advance to a joint venture company which was declared sick by BIFR and advance had become bad. Ld. A.R. submitted that Hon'ble Supreme Court had held that the said amount was allowable as deduction when it was written off in the 10 ITA No.902/Del/2009 books of account. Ld. A.R. further submitted that the case of assessee is also supported by Hon'ble Supreme Court decision in the case of TRF Ltd. vs CIT 323 ITR 397. He submitted this principle of law has been held by Hon'ble Jurisdictional High Court in the case of CIT Vs D B India Securities Ltd. 187 Taxman 161. He submitted that the amount represented recoverable debt from Govt. and arose out of valid transaction of purchase of stamp papers which was for bona fide purposes of the assessee's business. He submitted that before it could be utilized the same were reflected in the balance sheets as business advance recoverable and when the assessee failed to recover the amount, it was written off and therefore he argued that the amount actually represented bad debt and, therefore, the ratio of Hon'ble Supreme Court in the case of TRF Ltd. was squarely applicable. Ld. A.R. further relied upon the following case law for the proposition that loss of bad debt is allowable in the year in which it is written off.:-
i) Harshad J. Choksi Vs CIT 349 ITR 250 (Bom.) ii) CIT vs New Delhi Hotels Ltd. 208 Taxman 280 iii) Mohan Meakin Ltd. Vs CIT 348 ITR 109 (Del.) iv) CIT Vs Samara India Pvt. Ltd. 216 Taxman 93 (Del.)
5. Continuing his arguments, Ld. A.R. submitted that due to continuous efforts, the assessee was able to recover a partial amount of Rs.74,11,018/- in Assessment Year 2008-09 which the assessee had included in its income in the said year, therefore he submitted that the assessee had incurred genuine business expenditure the deduction of which has been denied whereas it has been taxed for amount which was recovered in the Assessment Year 2008-09. The Ld. A.R. further distinguished the case law relied upon by A.O. 11 ITA No.902/Del/2009
6. Ld. D.R. on the other hand argued that the expenses were not incurred in the year under consideration and therefore, expenses claimed by assessee cannot be said to have been incurred in the year under consideration. It was submitted that the assessee was following mercantile system of accounting and under mercantile system of accounting, only those expenses and income are included for computation of business profits which are incurred or accrued during the year and therefore he strongly argued that the authorities below have rightly denied deduction. Ld. D.R. further argued that assessee neither incurred expenditure during this year nor it can be said that non recovery of cost of stamp papers had become final in this year as the Collector Gurgaon had rejected the application of assessee vide order dated 08.02.2003 which falls in Assessment Year 2003-04.
7. We have heard rival parties and have gone through the material placed on record. This case was earlier heard on 12.03.2015. During the course of dictation it was felt that Ld. A.R. had not clarified certain objections raised by Ld. CIT(A) as contained in Sl. N.1-5 at page 03 of his order and therefore the case was refixed and was finally heard on 15.05.2015, where, Ld. A.R. filed an additional synopsis wherein he clarified the objections raised by Ld. CIT(A). From the facts of the case, following undisputed facts emerged:-
i) The assessee is engaged in the business of development of real estate and 39 companies merged with the assessee company w.e.f. 01.04.1999 by the order of Hon'ble High Court.
ii) Out of 39 companies, 19 companies had purchased stamp papers in the Assessment Year 2001-02 which could not be utilized for execution of sale deed, therefore, 10% of the cost of stamp papers 12 ITA No.902/Del/2009 were written off in the books of account in the Assessment Year 2002-
03. The assessee applied to Collector Gurgaon for refund of 90% of cost of stamp papers during Assessment Year 2002-03.
iii) The Collector Gurgaon rejected the application of assessee vide order dated 08.02.2003, the copy of such order has been claimed to have been received by assessee on 20.07.2005.
iv) During Assessment Year 2008-09, the Ld. A.R. has claimed to have received refund of Rs.74,11,018/-, out of claim of the cost of stamp papers which the Ld. A.R. had claimed to have been offered as income in the said Assessment Year.
8. From the above facts and circumstances, it is apparent that the expenses for purchase of stamp papers were not incurred in the year under consideration. Now, the question is as to whether the expenses incurred in earlier year can be deemed be relating to the year under consideration on the basis of claim of assessee that the same were written off in the books of accounts in the present year.
9. Ld. A.R. has advanced an argument that the case of assessee was duly covered by Hon'ble Supreme Court decision in the case of Kerala State Industrial Development Corpn. Ltd. and TRF Ltd. as the claim of assessee was allowable in the year in which the amounts were written off. In relying upon these decisions, the Ld. A.R. has tried to equate the expenses incurred in earlier year as advances recoverable which to our mind is not a correct proposition. We find that the case laws relied upon by Ld. A.R. relates to bad debts written off whereas the present case is not that of bad debt written off and, therefore, the case laws relied upon by Ld. A.R. are not applicable to the facts of the present case and even the ratio of these cases 13 ITA No.902/Del/2009 cannot be applied to the facts and circumstances of the present case. The provisions relating to bad debts are contained in Section 36(2)(i) which reads as under:
"S.362)(i): no such deduction shall be allowed unless such debt or part thereof has been taken into account in computing the income of the assessee of the previous year in which the amount of such debt or part thereof is written off or of an earlier previous year, or represent money lent in the ordinary course of the business of banking or money lending which is carried on by the assessee."
10. From the above provisions it is apparent that the section states that only those bad debts will be allowed as deduction, which have been taken into account in computation of income of assessee in the same year or some earlier year. Whereas in the present case, the amount of claim of write off does not constitute writing off it as bad debt and rather it is a case of claim of expense which was incurred in the course of business of assessee and which had to be claimed in the year in which it was incurred as the assessee was following mercantile system of accounting. If the assessee had not claimed the same in the year of its incurrence as it was hopeful of recovering the same then such claim can be written off in the year in which assessee came to know that claim cannot be recovered. The order of collector rejecting the application for refund of amounts is dated 08.02.2003 which means that order was pronounced in the Assessment Year 2003-04, therefore, at best, the assessee could have claimed the same in Assessment Year 2003-04. The final accounts are prepared at least after three-four months from the date of closing. Therefore, there was sufficient time period available to assessee for writing off the claim in Assessment Year 2003-04. Therefore, the deduction claimed in the year under consideration cannot be 14 ITA No.902/Del/2009 said to have materialized in the present year specifically in view of the fact that assessee received part of claim in Assessment Year 2008-09, which implies that fact of non recovery of cost of stamp papers became final in Assessment Year 2008-09.
11. As per provisions of the income tax Act, income tax is chargeable on the income of an assessee and income has to be calculated in accordance with provisions of this Act and further every year is a separate Assessment Year.
12. As per section 145 of the I. T. Act, 1961, the income chargeable under the head profits and gains of business and profession is to be computed in accordance with cash or mercantile system of accounting as regularly employed by the assessee. Under mercantile system of accounting, all expenses relating to the year and all incomes relating to the year are considered in the year of its incurrence or accrual. Admittedly, the assessee w as following mercantile system of accounting as is noted on the face of assessment order itself and, therefore, the claim of assessee is not tenable in the year under consideration as the expenses were neither incurred in the year nor expenses got materialized during the year.
13. The Hon'ble Supreme Court in the case of Indermani Jaite Vs CIT 35 ITR 298 commenting upon the mercantile system of accounting, has observed as under:
"It is well known that the mercantile system of accounting differs substantially from the cash system of book-keeping. Under the cash system, it is only actual cash receipts and actual cash payments that are recorded as credits and debits; whereas, under the mercantile system, credit entries are made in respect of amounts due immediately they become legally due and before they are actually received; similarly, the expenditure items for which legal liability has been 15 ITA No.902/Del/2009 incurred are immediately debited even before the amounts in question are actually disbursed. Where accounts are kept on mercantile basis, the profits or gains are credited though they are not actually realized, and the entries thus made really show nothing more than an accrual or arising of the said profits at the material time. The same is the position with regard to debits made."
14. From the above observations, we find that in the mercantile system of accounting expenses or income are allowed on the basis of incurrence or accrual. The expenditure was not incurred during the year under consideration, nor the expenses can be said to have materialized during the year as discussed earlier in the order, therefore, we hold that expenses incurred on cost of stamp paper has rightly been disallowed by authorities below. The case law relied upon by Ld. A.R. are distinguishable as the case laws relates to write off of book debts whereas the present case relates to allow ability of expenses. In view of the above ground No.2 is dismissed. The Ld. A.R. did not argue on ground No.3 & 4, therefore, these are dismissed as not pressed. Ground No.1 is general ground and do not require any adjudication.
15. However, Ld. A.R. has claimed that in Assessment Year 2008-09, an amount of Rs.74,11,018/- was received against claim and was offered to tax. The taxation of this amount in Assessment Year 2008-09 will amount to double taxation to this extent. Therefore, we hold that his amount of Rs.74,11,018/- needs to be reduced from the disallowance made during the year under consideration subject to verification by A.O. Therefore, we are of the opinion that the case of assessee be remitted back to the office of A.O. who on the basis of documents and returns and accounts of assessee for Assessment Year 2008-09 will examine the claim of Ld. A.R. regarding 16 ITA No.902/Del/2009 offering of such amount in the return of income and if the same is found to have been offered in such assessment year then he will reduce this amount from disallowance made in the year under consideration.
13. In view of above, appeal of assessee is partly allowed for statistical purposes.
14. Order pronounced in the open court on 10th June, 2015.
Sd./- Sd./-
( G. C. GUPTA) (T.S. KAPOOR)
VICE PRESIDENT ACCOUNTANT MEMBER
th
Date: 10 June, 2015
Sp
Copy forwarded to:-
1. The appellant
2. The respondent
3. The CIT
4. The CIT (A)-, New Delhi.
5. The DR, ITAT, Loknayak Bhawan, Khan Market, New Delhi. True copy.
By Order (ITAT, New Delhi).
S.No. Details Date Initials Designation
1 Draft dictated on 22/5 Sr. PS/PS
2 Draft placed before author 26,27,8,9,9, Sr. PS/PS
Draft proposed & placed before the
3 JM/AM
Second Member
Draft discussed/approved by Second
4 AM/AM
Member
Approved Draft comes to the Sr. 10/6/15
5 Sr. PS/PS
PS/PS
6 Kept for pronouncement 10/6 Sr. PS/PS
7 File sent to Bench Clerk 10/6 Sr. PS/PS
Date on which the file goes to Head
8
Clerk
9 Date on which file goes to A.R.
10 Date of Dispatch of order