Subject: Salesman incentives and other reimbursement to RDS.
Referred Sections:
Section 201(1)
Section 194C of the Income-tax Act,
Section 194C of the Act.
Section 201(1) of the Act.
Section 271C of the Income-tax Act,
Section 194H
Section 211 of the Companies Act,
Section 194J of the Income Tax Act,
Referred Cases / Judgments
Jagran Prakashan Ltd. vs. DCIT(TDS) 345 ITR 288 (All HC)
Aligarh Muslim University vs. ITO 189 TTJ 794 (Agra ITAT).
1 ITA No. 2286/Del/2016 & ors
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH: `F' NEW DELHI
BEFORE SHRI O.P. KANT, ACCOUNTANT MEMBER
AND
MS SUCHITRA KAMBLE, JUDICIAL MEMBER
ITA No.2289/DEL/2016 ( A.Y 2011-12)
Spice Mobility Ltd. Vs Addl. CIT(TDS)
19A & 19B, Floor No. 5 Noida
Global Knowledge Park, Sector-125
Noida AABCM5619D (RESPONDENT)
(APPELLANT)
ITA No.2286//DEL/2016 ( A.Y 2011-12)
Spice Mobility Ltd. Vs ACIT(TDS)
19A & 19B, Floor No. 5 Noida
Global Knowledge Park, Sector-125
Noida AABCM5619D (RESPONDENT)
(APPELLANT)
ITA No.2288/DEL/2016 ( A.Y 2012-13)
Spice Mobility Ltd. Vs ACIT(TDS)
19A & 19B, Floor No. 5 Noida
Global Knowledge Park, Sector-125
Noida AABCM5619D (RESPONDENT)
(APPELLANT)
ITA No.2287/DEL/2016 ( A.Y 2012-13)
Spice Mobility Ltd. Vs ACIT(TDS)
19A & 19B, Floor No. 5 Noida
Global Knowledge Park, Sector-125
Noida AABCM5619D (RESPONDENT)
(APPELLANT)
Appellant by Sh. Ajay Vohra, Sr. Adv, Sh.
Aditya Vohra, Adv & Ms.
Meenal Goyal, CA
Respondent by Sh. Atiq Ahmed, Sr. DR
2 ITA No. 2286/Del/2016 & ors
Date of Hearing 25.06.2018
Date of Pronouncement 19.09.2018
ORDER
PER SUCHITRA KAMBLE, JM
These appeals are filed by the assessee against the order dated
29/02/2016 passed by CIT(A)-1, Noida.
2. The grounds of appeal are as under:-
ITA No.2289/DEL/2016 (A.Y. 2011-12)
1. That on the facts and circumstances of the case and in law, the
CIT(A) erred in confirming the order of the assessing officer holding the
appellant to be an assessee in default under section 201(1) for the alleged
failure to deduct tax at source under section 194C of the Income-tax Act, 1961
(`the Act') from the amount reimbursed to Regional Distributors (`RDs') in
respect of advertisement expenses incurred by them.
1.1. That on the facts and circumstances of the case and in law, the
CIT(A) erred in not appreciating that the Regional Distributors (`RDs') were not
advertising agencies and did not carry out any advertising work for the
appellant and the advertisement expenditure reimbursed to them did not fall
within the ambit of section 194C of the Act.
1.2. That on the facts and circumstances of the case and in law, the
CIT(A) erred in not holding that no tax was required to be deducted under
section 194C of the Act from advertisement expenses reimbursed to RDs as
there was no income element embedded therein.
1.3. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in not holding that tax not deducted at source
under section 194C from advertising expenses reimbursed to RDs, was not
recoverable from the appellant, being the payer, under section 201(1) of the
Act.
2. That on the facts and circumstances of the case and in law, the
CIT(A) erred in not deleting interest of Rs.15,41,531 charged under section
3 ITA No. 2286/Del/2016 & ors
201(1 A) of the Act in respect of tax alleged to be deductible under section
194C of the Act but not deducted from advertisement expenses reimbursed to
RDs.
2.1. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in confirming levy of interest of Rs.15,41,531
under section 201(1 A) of the Act without appreciating that the same had not
been computed correctly by the assessing officer.
2.2. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in not appreciating that the interest under section
201(1 A) of the Act was chargeable, if at all, from the date of payment/ credit
to the due date of filing return of income by the payee.
3. That on the facts and circumstances of the case and in law, the
C1T(A) erred in confirming the order of the assessing officer levying interest
under section 201(1 A) of the Act, for the alleged failure of the appellant to
deduct tax at source under section 192(1) of the Act, from the amount paid
towards salary, at average rate of tax.
3.1. Without prejudice, that on facts and circumstances of the case and
in law, the C1T(A) erred in not appreciating that there is no overall short
deduction of tax under section the Act and interest could not be levied on the
basis of monthly shortage U/S 201(1a) of the Act.
4. That on the facts and circumstances of the case and in law, the
C1T(A) erred in confirming the order of the assessing officer levying interest
under section 201(1A) of the Act on the provision made for recruitment
expenses.
5. That on the facts and circumstances of the case and in law, the
CIT(A) erred in confirming the order of the assessing officer levying interest for
alleged late deposit of TDS under section 201(1 A) of the Act, in respect of
provision made for commission to directors.
ITA No.2286/DEL/2016 (A.Y. 2011-12)
1. That the CIT(A) erred on facts and in law in confirming the order passed
under section 271C of the Income-tax Act, 1961 (`the Act') by the assessing
officer levying penalty of Rs.36,70,312 for alleged failure to deduct tax at
source from reimbursement of advertisement expenses.
4 ITA No. 2286/Del/2016 & ors
2. That on the facts and circumstances of the case and in law, the CIT(A)
erred in not appreciating that the appellant had `reasonable cause' for not
deducting tax at source from the aforesaid payment as the appellant was
under bona fide belief that the same were not subject to tax deduction at
source under Chapter XVII-B of the Act.
The appellant craves leave to add to, amend, alter or vary the above grounds
of appeal at or before the time of hearing.
ITA No.2288/DEL/2016 (A.Y. 2012-13)
1. That on the facts and circumstances of the case and in law, the
CIT(A) erred in confirming the order of the assessing officer holding the
appellant to be an assessee in default under section 201(1) for the alleged
failure to deduct tax at source under section 194C of the Income-tax Act, 1961
(The Act') from the amount reimbursed to Regional Distributors (`RDs') in
respect of advertisement expenses incurred by them.
1.1. That on the facts and circumstances of the case and in law, the
CIT(A) erred in not appreciating that the Regional Distributors ('RDs') were not
advertising agencies and did not carry out any advertising work for the
appellant and the advertisement expenditure reimbursed to them did not fall
within the ambit of section 194C of the Act.
1.2. That on the facts and circumstances of the case and in law, the
CIT(A) erred in not holding that no tax was required to be deducted under
section 194C of the Act from advertisement expenses reimbursed to RDs as
there was no income element embedded therein.
1.3. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in not holding that tax not deducted at source
under section 194C from advertising expenses reimbursed to RDs, was not
recoverable from the appellant, being the payer, under section 201(1) of the
Act.
2. That on the facts and circumstances of the case and in law, the
CIT(A) erred in not deleting interest of Rs.78,173 charged under section 201(1
A) of the Act in respect of tax alleged to be deductible under section 194C of
the Act but not deducted from advertisement expenses reimbursed to RDs.
2.1. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in confirming levy of interest of Rs.78,173 under
5 ITA No. 2286/Del/2016 & ors
section 201(1 A) of the Act without appreciating that the same had not been
computed correctly by the assessing officer.
2.2. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in not appreciating that the interest under section
201(1 A) of the Act was chargeable, if at all, from the date of payment/ credit
to the due date of filing return of income by the payee.
3. That on the facts and circumstances of the case and in law, the
CIT(A) erred in confirming the order of the assessing officer levying interest
under section 201(1 A) of the Act, for the alleged failure of the appellant to
deduct tax at source under section 192(1) of the Act, from the amount paid
towards salary, at average rate of tax.
3.1. Without prejudice, that on the facts and circumstances of the case
and in law, the C1T(A) erred in not appreciating that there is no overall short
deduction of tax under section 192(1) of the Act and interest could not be
levied on the basis of monthly shortage under section 201(1 A) of the Act.
4. That on the facts and circumstances of the case and in law, the
CIT(A) erred in confirming the order of the assessing officer holding the
appellant to be an assessee in default under section 201(1) for non-deduction
of tax at source under section 194H in respect of provision made for
recruitment expenses.
4.1. That on the facts and circumstances of the case and in law, the
C1T(A) erred in not appreciating that provisions of section 194H of the Act
were not applicable in respect of aforesaid amount payable towards
recruitment expenses.
4.2. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in not holding that tax alleged to be deductible
under section 194H of the Act from aforesaid amount payable towards
recruitment expenses, was not recoverable'' from the appellant, being the
payer, under section 201(1) of the Act.
5. That on the facts and circumstances of the case and in law, the
C1T(A) erred in not deleting interest of Rs.24,693 charged under section 201(1
A) of the Act from the aforesaid amount payable towards recruitment
expenses, alleged to be deductible under section 194H of the Act.
6. That on the facts and circumstances of the case and in law, the
6 ITA No. 2286/Del/2016 & ors
CIT(A) erred in confirming the order of the assessing officer holding the
appellant to be an assessee in default under section 201(1) for non-deduction
of tax at source on payments made for testing expenses.
6.1. That on the facts and circumstances of the case and in law, the
CIT(A) erred in affirming the order passed under section 201(1) without
appreciating that the assessing officer failed to specify under which section
the appellant defaulted in deducting tax at source on payments made
towards testing expenses.
6.2. That without prejudice, on the facts and circumstances of the case
and in law, the CIT(A) erred in not holding that tax alleged to be deductible
from aforesaid amount paid towards testing expenses, was not recoverable
from the appellant, being the payer, under section 201(1) of the Act.
7. That on the facts and circumstances of the case and in law, the
C1T(A) erred in not deleting interest of Rs.7,951 charged under section 201 (1
A) of the Act from the aforesaid amount payable towards testing expenses.
The appellant craves leave to add to, amend, alter or vary the above grounds
of appeal at or before the time of hearing.
ITA No.2287//DEL/2016 (A.Y. 2012-13)
1. That the CIT(A) erred on facts and in law in confirming the order passed
under section 271C of the Income-tax Act. 1961 (`the Act') by the assessing
officer levying penalty of Rs.4,01,140 for alleged failure to deduct tax at
source from reimbursement of advertisement expenses, recruitment expenses
and testing expenses.
2. That on the facts and circumstances of the case and in law, the CIT(A)
erred in not appreciating that the appellant had `reasonable cause' for not
deducting tax at source from the aforesaid payment as the appellant was
under bona fide belief that the same were not subject to tax deduction at
source under Chapter XVII-B of the Act.
The appellant craves leave to add to, amend, alter or vary the above grounds
of appeal at or before the time of hearing.
3. Firstly, we take up A.Y. 2011-12. The assessee is a public limited
company engaged in the business of trading of mobile phones handsets,
manufacturing trading, servicing, maintenance of computer hardware. The
7 ITA No. 2286/Del/2016 & ors
assessee for the Financial Year 2010-11 filed quarterly returns of tax deducted
at source under various sections on due dates. The proceedings relating to
verification of quarterly TDS returns, were initiated by the Assessing Officer,
after which order dated 28.03.2014 was passed under section 201(1)/201(1A)
of the Income Tax Act, 1961, treating the assessee as an 'assessee in default'
for failure to deduct tax at source from certain payments during the relevant
previous year. The assessee, during the relevant previous year, paid Rs.
18,35,15,604/- to regional distributors on account of reimbursement of
expenses against third party bills, incurred by them for advertisement in
relation to the assessee's products sold by them on their own account. These
expenses included manpower reimbursement to RDS, Salesman incentives and
other reimbursement to RDS. In the Assessment Order, the Assessing Officer
held the assessee as "assessee in default" under section 201 (1) of the Act and
also levied interest under section 201 (1A) of the Act, in respect of failure to
deduct tax at source in respect of the aforesaid payments made to various
distributors/dealers. During the relevant previous year, the assessee deducted
tax at source amounting to Rs. 2,22,40,792/- from the amounts paid as salary.
The rate of tax deducted at source was calculated at "average rate of income-
tax" computed on the basis of the rates in force on the estimated income of the
payee for the relevant financial year. The Assessing Officer computed the
amount of tax to be deducted on month to month basis of average tax
deducted.
4. Being aggrieved by the order u/s 201(1)/201(1A) of the Act, the assessee
filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee.
5. As regards Ground Nos.1, 1.1, 1.2 and 1.3, relating to failure to deduct
tax at source u/s 194C of the Act from the amount reimbursed to regional
distributors in respect of advertisement expenses incurred by them, the Ld. AR
submitted that as per Clause 2.6 of the agreement, the distributor is not the
agent. Therefore, this is the amount paid from principal to principal.
8 ITA No. 2286/Del/2016 & ors
Therefore, the reimbursement of this amount was claimed by the assessee.
For Assessment Year 2009-10, the Tribunal in case of M/s. S. Mobility Ltd.
(ITA No. 3898/Del/2013 and CO No. 245/Del/2013 order dated 29.12.2014)
held that the tribunal agree with the contention of the assessee that no TDS
provisions are attracted where it is a purely reimbursement and there was no
profit element for the payee, as held by the CIT(A), but the Tribunal further
held that however, it was a structure arrangement wherein the payments are
routed through the distributors to circumvent the provisions of Chapter XVII-B
of the Act. The Tribunal further observed that the bill raised by the
advertisement agency was not in the name of the distributor, therefore, the
Tribunal remanded back the issue to the file of the AO and directed the
assessee to produce the evidences before the Assessing Officer to establish
that the parties to whom the reimbursements have been made had actually
complied with the provisions of Chapter XVII-B. The Ld. AR submitted that in
the present case the assessee was raised the bill in the name of payee, the
CIT(A) has taken into account of these factors and it's a cryptic order. The Ld.
AR further submitted that there is no element of profit involved. The Ld. AR
relied upon the Hon'ble Allahabad High Court decision in case of Jagran
Prakashan Ltd. vs. DCIT(TDS) 345 ITR 288 (All HC) which was followed by
Agra Bench of the Tribunal in case of Aligarh Muslim University vs. ITO 189
TTJ 794 (Agra ITAT).
6. The Ld. DR relied upon the Assessment Order and the order of the
CIT(A). The Ld. DR submitted that the assessee has failed to deduct tax as and
from the record it shows that deductor is in default for having not deducted the
TDS on the amounts of Rs.18,35,15,604/- for Financial Year 2010-11 and Rs.
1,30,28,911/- for the Financial Year 2011-12 and is liable for the TDS u/s
194C which amounts to Rs.183,515,604/- under the head of publicity
expenses for Assessment Year 2010-11 and Rs. 13,028,911/- for Financial
Year 2011-12. Since, the assessee has not produce any details the Assessing
Officer has rightly made the addition.
9 ITA No. 2286/Del/2016 & ors
7. We have heard both the parties and perused the material available on
record. From the Tribunal's decision in the assessee's own case for
Assessment Year 2009-10. The Tribunal has categorically given finding that
there was a structure arrangement wherein the payments are rooted through
the distributors to circumvent the Provisions of Chapter XVII-V of the Act.
Therefore, the Tribunal has confirmed the CIT(A)'s direction as to directing the
assessee to produce the evidences before the Assessing Officer to establish
that the parties to whom the reimbursement have been made had actually
complied with the provisions of Chapter XVI-V. In the present Assessment
Year, the assessee during the previous year paid Rs. 18,35,15,604/- to
regional distributors on account of reimbursement of expenses against third
party bills, incurred by them for advertisement in relation to the assessee's
products sold by them on their own account. From the records it is seen that
these expenses included manpower reimbursement to RDS, Salesman
incentives and other reimbursement to RDS. Thus, the assessee raised the bill
in the name of payee and the assessee also produced evidences before the
Assessing Officer to establish that the parties to whom the reimbursement
have been made had actually complied with the Provisions of Chapter XVII-V.
Therefore, we are of the view that the CIT(A) has not looked into the evidences
produced before the Assessing Officer as well as before CIT(A). Thus, Ground
Nos. 1, 1.1, 1.2 and 1.3 of assessee's appeal are allowed.
8. As related to Ground No. 2, 2.1 and 2.2 regarding levy of interest the
same is consequential, hence the same do not require adjudication.
9. As regards Ground No. 3 and 3.1 relating to levy of interest under
Section 201(1A) of the Act, for the alleged failure of the appellant to deduct tax
at source under section 192(1) of the Act, from the amount paid towards
salary, at average rate of tax, as well as short deduction of tax the interest
levied on the basis of monthly shortage u/s 201(1A), the Ld. AR submitted that
the Assessing Officer, wrongly levied interest under section 201 (1A) of the Act
10 ITA No. 2286/Del/2016 & ors
for the alleged failure to deduct tax at source under section 192 (1) of the Act,
from the amount paid towards salary. The Ld. AR further submitted that the
Assessing officer failed to appreciate that where there is no overall short
deduction of tax under section 192 (1) of the Act, interest cannot be levied on
the basis of monthly shortage under Section 201 (1A) of the Act. The Ld. AR
further submitted that the assessee company made a provision for recruitment
expenses, where TDS has been deducted at the time of actual payment or
credit to the party. Thus there is no default in TDS deduction. However, the
Assessing Officer levied the interest under section 201(1A) of the Act.
10. The Ld. DR relied upon the Assessment Order and the order of the
CIT(A).
11. We have heard both the parties and perused all the relevant material
available on record. From the records it can be seen that during the relevant
previous year, the assessee deducted tax at source amounting to Rs.
2,22,40,792/- from the amounts paid as salary. The rate of tax deducted at
source was calculated at "average rate of income tax" computed on the basis of
the rates on the estimated income of the payee for the relevant financial year.
But the Assessing Officer proceeded to compute the amount of tax to be
deducted on month to month basis of average tax deducted. This needs to be
verified as the Ld. AR made submission before us that the Assessing Officer
has not given any credit for interest where there is no surplus payment of TDS,
while charging interest on deficit amount. Thus, this issue is remanded back
to the file of the Assessing Officer for verifying as to whether the interest clause
is applicable or not and if applicable whether there is surplus payment of TDS
or not. After verifying the same the Assessing Officer decide this issue.
Needless to say, the assessee be given opportunity of hearing by following
principles of natural justice. Thus, Ground Nos. 3 and 3.1 are partly allowed
for statistical purpose.
11 ITA No. 2286/Del/2016 & ors
12. As related to Ground No. 4, regarding provisions made for recruitment
expenses, the Ld. AR submitted that the assessee company made a provision
for recruitment expenses, where TDS has been deducted at the time of actual
payment or credit to the party. Thus, the Ld. AR submitted that there is no
default in TDS deduction. The Ld. AR further submitted that the action of the
Assessing Officer in treating the assessee as an "assessee-in-default" and
levying interest under Section 201(1A) of the Act is thus not based on proper
appreciation of the facts of the case.
13. The Ld. DR relied upon the order of the Assessing Officer and the order
of the CIT(A).
14. We have heard both the parties and perused all the material available on
record. It can be seen that the assessee company made a provision for
recruitment expenses, where TDS has been deducted at the time of actual
payment or credit to the party. Thus, there is no default in TDS deduction.
Therefore, the action of the Assessing Officer in treating the assessee as an
"assessee-in-default" and levying interest under Section 201(1A) of the Act is
not based on proper appreciation of the facts of the case. Ground No. 4 is
allowed.
15. As relates to Ground No.5, commission to the Director, the Assessing
Officer has not made any deduction that only interest has been levied. The Ld.
AR submitted that the assessee made a provision for commission to directors
at the end of the year, which can be paid strictly in accordance with Section
211 of the Companies Act, 1956 and TDS can be deducted and paid, when
actual liability is ascertained, which generally happens after five/six months
from the end of the financial year. Further, in Finance Bill, 2012, Section 194J
of the Income Tax Act, 1961 has been amended and a clause (ba) to sub
section (1) of the Section 194J effective from 1st July, 2012 has been
Introduced wherein tax is required to be deducted on the remuneration paid to
director, which is not in nature of salary, at the rate of 10% of such
12 ITA No. 2286/Del/2016 & ors
remuneration. Thus, this clause is applicable w.e.f. 1.07.2012. However, the
Assessing Officer levied the interest under section 201(1A) of the Act.
16. The Ld. DR relied upon the order of the Assessing Officer and the order
of the CIT(A).
17. We have heard both the parties and perused all the relevant material
available on record. The assessee made a provision for commission to directors
at the end of the year, which can be paid strictly in accordance with Section
211 of the Companies Act, 1956 and TDS can be deducted and paid, when
actual liability is ascertained, which generally happens after five/six months
from the end of the financial year. Further, in Finance Bill, 2012, Section 194J
of the Income Tax Act, 1961 has been amended and a clause (ba) to sub
section (1) of the Section 194J effective from 1st July, 2012 has been
Introduced wherein tax is required to be deducted on the remuneration paid to
director, which is not in nature of salary, at the rate of 10% of such
remuneration. Thus, the contention of the Ld. AR that this clause is applicable
w.e.f. 1.07.2012 is just and proper. Ground No. 5 is allowed.
18. In result, appeal being ITA No. 2289/DEL/2016 for A.Y. 2011-12 filed by
the assessee is partly allowed for statistical purpose.
19. For Assessment Year 2012-13 being ITA No.2288/DEL/2016, except
ground nos. 6, 6.1, 6.2 and 7 the rest of the grounds are identical to the earlier
assessment year i.e. 2011-12. The Ground Nos. 6, 6.1, 6.2 and 7 regarding
testing expenses. The Ld. AR submitted that payment made for purchase of
material and not in nature of service. Thus, interest cannot be levied. The Ld.
DR relied upon the orders of the Assessing Officer and the CIT(A).
20. We have heard both the parties and perused all the relevant material
available on record. As regards Ground Nos. 1, 1.1, 1.2 and 1.3 as well as
Ground Nos. 2, 2.1 and 2.2 are identical in nature to that of A.Y. 2011-12,
hence, allowed. As regards Ground Nos. 3 and 3.1 are identical in nature to
13 ITA No. 2286/Del/2016 & ors
that of A.Y. 2011-12 and hence partly allowed for statistical purpose. As
regards Ground Nos. 4, 4.1 and 4.2 as well as 5 are identical in nature to that
of A.Y. 2011-12, hence, allowed. As regards Ground Nos. 6, 6.1, 6.2 and 7,
from the records it can be seen that payment made for purchase of material
and not for services and thus, the Assessing Officer as well as the CIT(A) was
not right in making the additions. Hence, Ground Nos. 6, 6.1, 6.2 and 7 are
allowed.
21. In result, appeal being ITA No. 2288/Del/2016 for A.Y. 2012-13 filed by
assessee is partly allowed for statistical purpose.
22. As regards, penalty u/s 271(1)(c) of the Income Tax Act, 1961 both the
Assessment Years are concerned, since the quantum for both the Assessment
Years are decided hereinabove, the same is consequential and hence partly
allowed for statistical purpose.
23. In result, appeals being ITA No.2286/Del/2016 for A.Y. 2011-12 and ITA
No. 2287/DEL/2016 for A.Y. 2012-13 are partly allowed for statistical purpose.
24. In result, all four appeals are partly allowed for statistical purpose.
Order pronounced in the Open Court on 19th September, 2018.
Sd/- Sd/-
(O. P. KANT) (SUCHITRA KAMBLE)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Dated: 19/09/2018
R. N*
Copy forwarded to:
1. Appellant
2. Respondent
3. CIT
4. CIT(Appeals)
5. DR: ITAT
ASSISTANT REGISTRAR
14 ITA No. 2286/Del/2016 & ors
ITAT NEW DELHI
Date of dictation 13.06.2018
Date on which the typed draft is placed before the 14.06.2018
dictating Member
Date on which the typed draft is placed before the
Other Member
Date on which the approved draft comes to the Sr.
PS/PS
Date on which the fair order is placed before the
Dictating Member for pronouncement
Date on which the fair order comes back to the Sr. 19.09.2018
PS/PS
Date on which the final order is uploaded on the 19.09.2018
website of ITAT
Date on which the file goes to the Bench Clerk 19.09.2018
Date on which the file goes to the Head Clerk
The date on which the file goes to the Assistant
Registrar for signature on the order
Date of dispatch of the Order
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