RATNAVEER PRECISION ENGINEERING LIMITED,VADODARA vs. THE ITO (TDS), WARD-2, VADODARA
What did the Tribunal hold?
The Tribunal held that the assessee failed to establish compliance with the statutory conditions for immunity from penalty under Section 271H(3) and also failed to demonstrate reasonable cause under Section 273B. The Tribunal noted that the revised TDS statement was filed only after the issuance of a show-cause notice under Section 201(1) and 201(1A), nearly three years and nine months after the original statement, which indicated a lack of bonafide intention. The Tribunal found that the assessee's explanation of an inadvertent error, coupled with subsequent correction, did not constitute a reasonable cause. However, considering the assessee's contention that the penalty was disproportionate and that a revised TDS return was eventually filed, the Tribunal reduced the penalty from Rs. 50,000 to Rs. 10,000 for each quarter. The grounds of appeal were dismissed, and the CIT(A)'s order was upheld subject to this reduction. The operative direction was for the AO to levy the reduced penalty.
What were the facts?
The assessee, Ratnaveer Precision Engineering Ltd., is appealing against penalty orders passed under Section 271H of the Income Tax Act, 1961, for the assessment years 2022-23 (Q-1 to Q-4), 2023-24 (Q-1 to Q-4), and 2024-25 (Q-1 to Q-4). These penalties arose from the failure to deduct tax at source (TDS) on freight payments made to transporters during Financial Year 2021-22. The Assessing Officer (AO) noted that the original TDS statements (Form 26Q) did not contain the requisite particulars of the transporters or the 'T' flag indicating exemption claims under Section 194C(6). The assessee argued that this was an inadvertent technical error, that revised TDS statements were filed, and that the transporters had provided declarations and PANs, and owned less than 10 trucks. The AO levied a penalty of Rs. 50,000 per quarter, which was confirmed by the CIT(A).
What were the issues?
1. Whether the penalty of Rs. 50,000 levied under Section 271H of the Income Tax Act, 1961, for each quarter is illegal and devoid of merit, considering the assessee's submission that the failure to flag the transporter code 'T' was an inadvertent and technical error, corrected by filing a revised TDS return prior to the finalization of proceedings under Section 201(1) of the Act. 2. Whether the penalty under Section 271H can be levied when the assessee was legally not required to deduct tax at source under Section 194C of the Act on payments made to transporters who owned less than 10 trucks and had filed declarations to that effect, and whether procedural or technical lapses should warrant a penalty. Assessee's Contentions: The omission to flag the transporter code 'T' was an inadvertent technical error, corrected by filing a revised TDS statement before the penalty order. The assessee had obtained PANs and declarations from transporters, and the transporters owned less than 10 trucks, making them exempt from TDS under Section 194C(6). The penalty is illegal and devoid of merit due to mere procedural lapses. The assessee relied on its written submissions and a paper book containing penalty orders and lower authority orders. Revenue's Contentions: The judgment does not explicitly record the revenue's specific contentions beyond the AO's actions and the CIT(A)'s findings.
Which sections of the Income-tax Act were involved?
Section 271H,Section 250,Section 194C,Section 201(1),Section 201(1A),Section 194C(6),Section 194C(7),Section 273B
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “SMC” BENCH, AHMEDABAD
Before: SHRI TAPAS RAM MISRA, JUDICIALMEMBER & SHRI GANGADHAR PANDA
IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, AHMEDABAD BEFORE SHRI TAPAS RAM MISRA, JUDICIALMEMBER & SHRI GANGADHAR PANDA, ACCOUNTANT MEMBER I.T.A. Nos.2265 to 2276/Ahd/2025 (Assessment Years:2022-23 (Q-1) to 2022-23 (Q-4), 2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4) Ratnaveer Precision Vs. Income Tax Officer (TDS), Engineering Ltd., Ward-2, E-77, GIDC Estate Manjusar, Vadodara Tal: Savli, Dist: Vadodara, Gujarat-391775 [PAN No.AABCR9648F] (Appellant) .. (Respondent) Appellant by: Shri Mahamadnurani Khatri, AR Respondent by: Shri Amit Pratap Singh, Sr. DR Date of Hearing 16.09.2026 Date of Pronouncement 28.10.2026 O R D E R PER GANGADHAR PANDA - ACCOUNTANTMEMBER: These bunch of captioned twelve appeals have been filed by the same assessee against the separate orders passed by the Ld. Commissioner of Income Tax (Appeals), (hereinafter referred to as “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi dated 29.09.2025, 30.09.2025 under Section 250 of the Income Tax Act, 1961, arising out of the penalty order dated 29.04.2025 completed under section 271H of the Income-tax Act, 1961 (“the Act”) for A.Y. 2022-23 (Q-1 toQ-4), A.Y. 2023-24 (Q-1 to Q-4) and A.Y. 2024-25 (Q-1 to Q-4) respectively. Since all the appeals involved identical/connected issues, the same were heard together and are, therefore, being disposed of by way of common order.
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
First we take up the assessee’s appeal in ITA No. 2265/Ahd/2025 (A.Y. 2022-23 Q-1)
The assessee has raised the following grounds of appeal:
“1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has grossly erred in confirming the penalty of Rs.50,000/- as levied by the Ld. AO u/s 271H of the Act. The Hon'ble ITAT is humbly requested to delete this penalty of Rs.50,000/- being the same as illegal and devoid of any merit. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has grossly erred in confirming the penalty of Rs.50,000/- as levied by the Ld. AO u/s 271H of the Act without considering the submission of the appellant which was duly filed to him at the time of appellate proceedings on legal and factual aspects. The Hon'ble ITAT is humbly requested to delete this penalty of Rs.50,000/- being the same as illegal and devoid of any merit. 3. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has grossly erred in confirming the penalty of Rs.50,000/- as levied by the Ld. AO u/s 271H of the Act without considering the facts that mere failure of the appellant to flag the Transporter code 'T' was an advertent and technical error and which was corrected by the appellant by way of filing revised TDS return prior to the finalization of the proceedings u/s 201(1) of the Act. In view of this the Hon'ble ITAT is humbly requested to delete this illegal penalty of Rs.50,000/- as levied by the Ld. AO u/s 271H of the Act. 4. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has grossly erred in confirming the penalty of Rs.50,000/- as levied by the Ld. AO u/s 271H of the Act despite the fact that the appellant was legally not required to deduct tax at source u/s 194C of the Act on the payments made to the transporters as each of the transporters was owning less than 10 trucks and they had filed declaration in this regard to the appellant. The Ld. CIT(A) failed to consider the fact that no penalty can be levied u/s 271H of the Act because of some procedural or technical lapses on the part of the appellant. The Ld. CIT(A) failed to consider the fact that the merit of the case of the appellant cannot be diluted because of some mere procedural lapse or technical fault. In view of this, the Hon'ble ITAT is humbly requested to delete this penalty of Rs.50,000/- as levied by the Ld. AO u/s 271H of the Act. 5. The appellant craves leave to add, alter or delete any of the aforesaid ground or grounds if necessary.”
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
All the grounds of appeal are interlinked, therefore, for the sake of convenience all these grounds of appeal are adjudicated together.
The brief facts of the case are that the assessee-company is engaged in the business of manufacturing finished sheets, pipes and other related products. A survey under section 133A(2A) of the Act was conducted in its case on 25.10.2024. Subsequently, on verification of the details available on the TRACES portal and the relevant ledgers furnished by the assessee, the Assessing Officer noticed that the assessee had made freight payments during Financial Year 2021-22 to transporters, namely - Apex Suri Logitech, Bajrang Transport, Nilaknth Transport and Shree Maruti Transport, amounting to Rs.3,28,319/-, Rs.28,01,346/-, Rs.10,97,377/- and Rs.28,73,731/- respectively, without deducting tax at source. The assessee's explanation was that the transporters had furnished declarations along with their PANs and that the payments were covered by the provisions of section 194C(6) of the Act. However, the Assessing Officer observed that the original TDS statement for the first quarter in Form 26Q filed on 29.07.2021 did not contain the requisite particulars of the transporters and the corresponding ‘T’ flag indicating the claim of exemption from deduction of tax.
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
The Assessing Officer further observed that the assessee had failed to report the relevant particulars in accordance with section 194C(7) of the Act read with Rule 31A(4)(vi) of the Income-tax Rules, 1962. In response to a show-cause notice dated 30.03.2025 for levying penalty under section 271H of the Act, the assessee submitted in its reply dated 04.04.2025 that the omission to mark the transporter code ‘T’ was an inadvertent technical error and that a revised TDS statement had been filed on 27.03.2025, correcting the omission. The assessee accordingly requested that the penalty proceedings be dropped.
The Assessing Officer, however, rejected the explanation on the ground that the revised statement had been filed on 27.03.2025, only after the issuance of a show-cause notice (SCN) under section 201(1) and section 201(1A) of the Act dated 22.03.2025 i.e. nearly three years and nine months after the original statement. According to the Assessing Officer, the failure to furnish the requisite particulars constituted incorrect and incomplete reporting within the meaning of section 271H(1)(b) of the Act. Accordingly, after obtaining the approval of the Joint Commissioner of Income Tax, TDS Range, Vadodara, the Assessing Officer levied a penalty of Rs.50,000/- for the first quarter of Financial Year 2021-22.
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
Aggrieved by the penalty order, the assessee preferred an appeal before the Ld. CIT(A).
The Ld. CIT(A), however, dismissed the appeal of the assessee, after discussing the provisions of section 271H(3) of the Act and observing that the assessee had failed to establish compliance with the statutory conditions for immunity from penalty. The Ld. CIT(A) also held that the assessee had not demonstrated reasonable cause for the default within the meaning of 273B of the Act and that the filing of a corrected statement only after the initiation of proceedings under section 201(1) and 201(1A) of the Act did not absolve it from the consequences of the original failure.
Aggrieved against the Ld CIT(A) order, therefore, the assessee filed appeal before us.
During the course of appellate proceeding before us, the Ld. Counsel has contended that the assessee had obtained the PANs and declarations from the transporters, and that the only lapse was the omission to mark the transporter code ‘T’ in the original TDS statement. The Ld. Counsel also stated that the revised statement was filed on 27.03.2025, before the passing of the penalty order, and that the correction demonstrated its bona fide intention to comply with the statutory requirements. In support of its contention, the Ld. Counsel has placed in a 226 5
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
pages Paper Book containing the penalty orders, CIT-A’s order and order u/s 201(1)/201(1A) for the relevant three years along with written submissions submitted before lower authorities. The Ld. Counsel also argued that the provisions of section 273B of the Act on reasonable cause were not properly considered and that the penalty was levied without adequately appreciating the nature and circumstances of the default.
In response, the Ld. Sr. DR placed reliance on the observations made by the AO and the Ld. CIT(A) in their respective orders, confirming the levy of penalty.
We have heard the rival submissions and perused the material available on record. We find that the penalty has been imposed primarily on account of the assessee's failure to report the requisite particulars of transporters including the freight amounts in the original TDS statement, and the transporter code ‘T’, after claiming the benefit of non-deduction of TDS as per section 194C(6) of the Act. The assessee's case is that the relevant PANs and declarations had been obtained and that the omission in the statement was an inadvertent procedural lapse which was subsequently rectified. This claim of assessee of having the requisite information at the time of filing TDS return had also been mentioned in the ‘Statement of Fact’ filed by the assessee in Form-35 before Ld. CIT(A), wherein assessee has
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
stated that “while filing the original quarterly TDS return in Form 26Q, due to inadvertence, the appellant failed to flag the relevant transporter code T for these payments, although all required declarations and PANs were duly obtained and preserved”. However, the glaring omission on the part of assessee at this point is that despite having obtained the information, the assessee has preserved the same to take benefits of the section 194C(6) but chose not to report the same to the tax authority, as required under section 194C(7) of the Act .Further the stated inadvertent error continued unabated in each quarter of relevant 3 years until potential tax liability issue raised upon the assessee through the Show Cause Notice (SCN) under section 201(1)/201(1A) of the Act. The dates of TDS quarterly return filed by the assessee for three consecutive years is tabulated below along with its revisions in response to SCN under section 201(1)/201(1A) and penalty notices:
Financial Original 26Q filing 201(1)(1A) Penalty notice Revised 26Q Filing Year Date SCN date u/s 271H date Date 2021-22 Q-1 29.07.2021 22.03.2025 30.03.2025 27.03.2025 Q-2 30.10.2021 22.03.2025 30.03.2025 27.03.2025 Q-3 04.02.2022 22.03.2025 30.03.2025 27.03.2025 Q-4 31.05.2022 22.03.2025 30.03.2025 27.03.2025 2022-23 Q-1 28.07.2022 22.03.2025 30.03.2025 26.03.2025 Q-2 23.11.2022 22.03.2025 30.03.2025 26.03.2025 Q-3 31.01.2023 22.03.2025 30.03.2025 26.03.2025 Q-4 29.05.2023 22.03.2025 30.03.2025 26.03.2025 2023-24 Q-1 20.09.2023 22.03.2025 30.03.2025 25.03.2025 Q-2 30.10.2023 22.03.2025 30.03.2025 25.03.2025 Q-3 29.01.2024 22.03.2025 30.03.2025 26.03.2025 Q-4 13.05.2024 22.03.2025 30.03.2025 25.03.2025
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
From above it is evident that until the SCN under section 201(1)/201(1A) was issued on 22.03.2025, the admitted inadvertent error by the assessee continued to repeat each year and the assessee had several occasions to avoid such inadvertent error while filing original TDS return in each quarter. However, the fact that each original TDS return had similar incomplete reporting gave force to the finding of the AO and Ld. CIT(A) that the assessee chose not to report the correct and complete declarations of transporters to the Income Tax Authority in violation of the statutory requirement stipulated under section 194C(7) of the I.T. Act r.w.r. 31A(4)(vi) of the I.T. Rule 1962.
We have further observed that the assessee in its reply dated 28.03.2025 to the aforesaid SCN under section 201(1)/(1A) of the Act has stated to have revised the TDS return (26Q) for first quarter of FY 2021-22, that no TDS has been made because the transporters have furnished declarations under section 196C(6) of the Act and that no details of such transporters with respective freight amounts along with remark “T” have been shown in the TDS quarterly return. It is also seen from the paper book filed by the assessee that the AO, after perusal of copies of declarations, has commented that the crucial information i.e. amount of freight payments to transporters were missing in the declarations of all transporters 8
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
furnished by the assessee, whereas sec 194C(7) of the Act stipulates reporting of such vital information as the basis for allowing non-deduction of tax by assessee u/s 194C(6) of the Act. Therefore, based on perusal of material available on records as well as the table above, we draw the inference that the assessee has repeatedly failed to discharge the responsibility of a deductor, as stipulated in section 194C(6) and 194C (7) of the Act, whereas the onus lies clearly on the assessee to accept complete and correct declarations from transporters, and to report the relevant details including PANs and freight amount paid in the TDS quarterly return as prescribed in IT Rules. 15. Under the above facts and circumstances, and based on the failure on the part of assessee to report correct and complete details in TDS Quarterly return in Form 26Q, it raises a question if indeed the assessee’s reason for committing the inadvertent error is bonafide. Add to this, no other reason is attributed that had prevented the assessee from reporting such information, as mandated in the statue, correctly and completely, if such relevant information had been already obtained by the assessee from the transporters in the form of declarations prior to the filing of TDS return in Form 26Q. Thus, the assessee's explanation that the omission was inadvertent and technical in nature, in our considered view, falls short of the threshold to constitute a reasonable cause for failure on the part of assessee. 9
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
In regard to the imposition of penalty under section 271H of the Act, the delay in revision has gone much beyond the section 271H(3) threshold of one year, and no compelling circumstances or sufficient explanation could be given by the assessee for this statutory default of incorrect reporting in TDS quarterly return in Form 26Q. The penalty under section 271H of the Act operates as independent levies and section 271H relief has specific statutory boundaries. Therefore, the relief under section 271H is contingent upon fulfilling all cumulative statutory exemption. However, the imposition of penalty under section 271H may be barred or deleted when the assessee establishes a reasonable cause under section 273B of the Act during the penalty proceeding. Section 273B of the Act expressly provides that no penalty shall be imposable in respect of the defaults covered by the said provision if the assessee proves that there was reasonable cause for the failure. Although statutory reporting obligations under Section 194C(7) of the Act are distinct from substantive non-deduction conditions, Section 273B independently shields an assessee from penalties upon proof of reasonable cause. Section 271H is included within the ambit of section 273B. Consequently, the question of reasonable cause under section 273B must independently be examined. The two provisions operate in different contexts, and the failure to satisfy the conditions of section 271H(3) does not, by itself, foreclose the assessee's claim under section 273B. In this 10
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
backdrop, in the present appeal, the Ld. CIT(A) order as well as the penalty order have adequately brought out the facts to show that the assessee's explanation as well as conduct devoid of bonafide intention and the requisite information is withheld from reporting to tax authorities as prescribed in the statute. Therefore, the plea of assessee that the omission is an inadvertent error coupled with subsequent correction do not convince us to constitute a reasonable cause for shielding the assessee from penalty.
Considering the totality of the facts and circumstances, we are of the view that the assessee by his actions has not satisfied the statutory conditions for immunity under section 271H(3) and also under separate defence available under section 273B of the Act. Therefore, the assessee is liable for penalty under section 271H of the Act. However, after considering the contention of the assessee that penalty levied by the AO is disproportionate to the statutory defaults committed by the assessee, and given the fact that the assessee has in the end revised the TDS return to comply with statutory requirements, we deem it fit to reduce the penalty to be levied on assessee under section 271H of the Act from Rs. 50,000/- to Rs 10,000/-.
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
Accordingly, we upheld the order of the Ld. CIT(A) on this issue subject to the finding above and direct the Assessing Officer to levy the penalty accordingly under section 271H of the Act for the first quarter of Financial Year 2021-22 relevant to Assessment Year 2022-23. The grounds of appeal raised by the assessee are dismissed.
In the result, the appeal of the assessee is dismissed.
Now we come to ITA Nos. 2266/Ahd/2025 to 2276/Ahd/2025 (A.Ys. 2022-23 (Q-2) to 2022-23 (Q-4), 2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4)
Since the facts and issues involved in all these appeals are identical to that have been discussed above in assessee’s appeal in ITA No. 2265/Ahd/2025 for A.Y. 2022-23 (Q-1), hence, our findings given above will apply mutatis mutandis to all these appeals also. Hence, the appeals of the assessee are also, accordingly, stands dismissed for all the assessment years.
In the combined result, all appeals filed by the assessee are dismissed. This Order pronounced in Open Court on 28/10/2026 Sd/- Sd/- (TAPAS RAM MISRA) (GANGADHAR PANDA) JUDICIAL MEMBER ACCOUNTANT MEMBER Ahmedabad; Dated 28/10/2026 Tanmay, Sr. PS TRUE COPY 12
ITA Nos. 2265 to 2276 /Ahd/2025 Ratnaveer Precision Engineering Ltd.vs. ITO(TDS) Asst.Years –2023-23 (Q-1) to 2022-23 (Q-4),2023-24 (Q-1) to 2023-24 (Q-4) and 2024-25 (Q-1) to 2024-25 (Q-4) JEETENDRA Digitally signed by JEETENDRA DEVENDRABHAI UPADHYAY DN: c=IN, o=PERSONAL, title=6087, आदेशकी�ितिलिपअ�ेिषत/Copy of the Order forwarded to : DEVENDRAB 2.5.4.20=7e5568a89b633f174b28a80f 1. अपीलाथ�/ The Appellant 5e63c638da40b7313fb47ebaefda841 cf59d1703, postalCode=380059, 2. ��थ�/ The Respondent. HAI st=Gujarat, 3. संबंिधतआयकरआयु�/ Concerned CIT serialNumber=816dc56e896211a1a21 ccc4abc94ddc94458f4a1b37be8e185 4. आयकरआयु�(अपील) / The CIT(A)- UPADHYAY 4e9399295106d4, cn=JEETENDRA 5. िवभागीय�ितिनिध, आयकरअपीलीयअिधकरण, अहमदाबाद/ DR, ITAT, Ahmedabad DEVENDRABHAI UPADHYAY Date: 2026.10.30 16:18:32 +05'30' 6. गाड�फाईल / Guard file. आदेशानुसार/ BY ORDER, उप/सहायकपंजीकार (Dy./Asstt.Registrar) आयकरअपीलीयअिधकरण, अहमदाबाद / ITAT, Ahmedabad
Date of dictation 19/22.10.2026 2. Date on which the typed draft is placed before the Dictating Member 19/22.10.2026 3. Other Member………………… 4. Date on which the approved draft comes to the Sr.P.S./P.S. 27.10.2026 5. Date on which the fair order is placed before the Dictating Member for pronouncement 28.10.2026 Date on which the fair order comes back to the Sr.P.S./P.S. 28.10.2026 6. 7. Date on which the file goes to the Bench Clerk 28.10.2026 Date on which the file goes to the Head Clerk…………………………………... 8. 9. The date on which the file goes to the Assistant Registrar for signature on the order…………………….. 10. Date of Dispatch of the Order……………………………………
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