IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCHES: `I-2', NEW DELHI
BEFORE SHRI R.K.PANDA, ACCOUNTANT MEMBER
AND SMT. BEENA A PILLAI, JUDICIAL MEMBER
ITA Nos. 8272/Del/2018
AY: 2013-14
&
ITA Nos. 8273/Del/2018
AY: 2014-15
Whirlpool of India Ltd. ACIT, LTU, Circle 1
Plot No.40, Sector 44 vs. NBCC Plaza
Gurgaon 122 002 Pushp Vihar
Haryana Saket
New Delhi 110 017
PAN: AAACW1336L
(Appellant) (Respondent)
Assessee by : Sh. Neeraj Jain, Adv.
Sh. Ramit Katyal, C.A.
Department by: Sh. H.K.Choudhary, CIT, DR
Date of Hearing : 18/02/2019
Date of Pronouncement: 25 .02.2019
ORDER
PER BEENA A PILLAI, JUDICIAL MEMBER
Present appeals have been filed by assessee against order
dated 30/11/2018 passed by DCIT LTU-1, New Delhi under
section 143(3) read with 144C of the Income Tax Act, 1961(the
Act). At the outset Ld. Counsel submitted that, grounds raised
by assessee in ITA No. 8273/Del/18 for AY 2014-15 are same
and identical. This fact has not been disputed by Ld.CIT DR and
therefore, we have taken these appeals to be disposed of, by way
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
of common order. For sake of convenience, grounds for
assessment year 2013-14 are reproduced hereunder:
1. That the impugned order of assessment framed by the officer in
pursuance of the directions of the Dispute Resolution Panel
(hereinafter referred to as `DRP') under Section 143(3) read with
Section 144C of the Income-tax Act, 1961 (`Act'), is bad in law,
violative of principles of natural justice and void ab-initio.
2. That on the facts and circumstances of the case and in law the
impugned order passed by the assessing officer is barred by
limitation and therefore, is liable to be quashed.
3. That the assessing officer erred on facts and in law in
determining income of the appellant at Rs. 1,78,31,84,906/-
against returned total income of Rs. 130,81,76,250/- under normal
provision of the Act.
3.1. That the assessing officer/DRP erred on facts and in law in
making addition of Rs.42,59,009/- on account of alleged
difference in the arm's length price of international transactions
resulting from the advertisement, marketing and sales promotion
expenses (hereinafter referred to as `the AMP expenses') incurred
by the appellant.
3.2. That the assessing officer/DRP erred on facts and in law in
not appreciating that the AMP expenses, etc., unilaterally incurred
by the appellant in India could not be characterised as an
international transaction as per section 92B, in the absence of any
proved understanding/arrangement between the appellant and
the associated enterprise, so as to invoke the provisions of section
92CA(3) of the Act.
3.3. That the DRP/TPO erred on facts and in law in holding that
there exists an international transaction in connection with
incurring of AMP expenses without placing on record any tangible
material or evidence to substantiate the existence of such
transaction.
3.4. That the DRP/TPO erred on facts and in law in not
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
appreciating that the only Transfer Pricing adjustment permitted
by Chapter X of the Act was in respect of the difference between
the arm's length price (ALP) and the contract or declared price, but
said provision could not be invoked to determine the
`quantum'/extent of business expenditure.
3.5. That the TPO erred on facts and in law in not following the
decision of the Hon'ble Delhi High Court in the appellant's own
case for A.Y. 2008-09 reported as 381 ITR 154 wherein the
Hon'ble High Court held that AMP expenses unilaterally incurred
by the appellant do not constitute an international transaction.
3.6. That the DRP/TPO erred on facts and in law in not
appreciating that since the appellant was performing the key
people/critical decision making functions with regard to
advertisement and marketing activity, the risk related to such
activity ought to have been borne by the applicant.
3.7. That the TPO erred on facts and in law in holding that
performance of Development, Enhancement, Maintenance,
Protection and Enhancement (`DEMPE') functions by the appellant
has led to international transaction between the appellant and the
associated enterprise not appreciating that such functions are
performed by the appellant independently, unilaterally and
without any influence of the associated enterprise.
3.8. That the TPO erred on facts and in law in not appreciating
that even otherwise since DEMPE functions relating to AMP
expenses are performed by the appellant and consequently the
returns attributed to such functions are also enjoyed by the
appellant in the form of higher sales and profitability, such AMP
expenses does not result in a service to the associated enterprise
warranting compensation.
3.9. That the TPO erred on facts and in law in not appreciating
that by virtue of long term right to use the `Whirlpool' brand in
India, the appellant has gained economic ownership of the said
brand.
3.10. That the DRP/TPO erred on facts and in law in arbitrarily
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
holding that the associated enterprise controls the development
and growth of its intangible not appreciating that in terms of the
global marketing policy of the Whirlpool group, the critical
decisions relating to incurring of AMP expenses are taken by the
board and management of the appellant independently.
3.11. That the DRP/TPO erred on facts and in law in arbitrarily
holding that with regard to export of goods the appellant is
operating as a contract manufacturer not appreciating that (i) the
appellant is operating as a full risk entrepreneur even with regard
to export of goods and is responsible for performing critical
decision making functions and (ii) the AMP expenses are incurred
by the appellant in India for promoting sale of products in the
Indian market.
3.12. That the DRP/TPO erred on facts and in law in not
appreciating that adjustment on account of allegedly excess AMP
expenses is not warranted in the case of the appellant, a full risk
bearing entrepreneur.
3.13. That the DRP/TPO erred on facts and in law in holding that
benefit derived by the associated enterprise as a result of AMP
expenses incurred by the appellant is reflected in the improvement
in overall global brand ranking not appreciating that such
improvement in ranking was a result of the strategic marketing
efforts and expenses incurred by the associated enterprises.
3.14. That the DRP/TPO erred on facts and in law in holding that
the associated enterprise is benefitting from the AMP expenses
incurred by the appellant on account of royalty, sale of goods etc.
Not appreciating that such transactions have been separately
benchmarked and accepted to be at arm's length.
3.15. That the DRP/TPO erred on facts and in law in holding that
the AE is benefitting from the AMP expenses on account of
development of brand without appreciating that the associated
enterprise is not selling any goods directly in the Indian market.
3.16. That the TPO erred on facts and in law in relying on the
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
decision of the Hon'ble Delhi High Court in the case of Sony
Ericsson Mobile communications 374 ITR 118 to hold that there
exists an international transaction between the appellant and the
associated enterprise in relation with incurring of AMP expenses
not appreciating that the said decision was rendered on the facts
of limited risk distributors and the existence of such transaction
was not in dispute therein.
3.17. That the TPO erred on facts and in law in making protective
adjustment of Rs.28,71,12,011 applying Bright Line Test (BLT) not
appreciating that use of BLT to infer the existence of an
international transaction is not mandated under the Act without
appreciating that in absence of specific provision in the Transfer
pricing statutory provisions in India, adjustment on account of the
arm's length price of the advertisement and brand promotion
expenses could not be made.
3.18. That the TPO erred on facts and in law in not appreciating
that the use of BLT has been negated by the Hon'ble Delhi High
Court in the case of Sony Ericsson Mobile communications 374 ITR
118.
3.19. Without prejudice that the DRP/TPO erred on facts and in
law in not appreciating that the AMP expenses incurred by the
appellant was appropriately established to be at arm's length
applying TNMM.
3.20. Without prejudice that the DRP/TPO erred on facts and in
law in not considering inappropriate comparable companies,
being contact manufacturers, for the purpose of applying the bright
line test not appreciating that such companies are not required to
incur any significant AMP expenses.
3.21. Without prejudice that the DRP/TPO erred on facts and in
law in considering inappropriate comparable companies for the
purpose of computing the mark up charged on AMP expenses.
4. That the Assessing Officer/DRP erred on facts and in law in
making disallowance of Rs.28,71,12,011/- u/s 37(1) of the Act on
account of advertisement and marketing expenses incurred by the
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
appellant holding that the expenditure was incurred by the
appellant for developing the brand in favour of the parent
company, being the legal owner of the brand.
4.1. That the assessing officer erred on facts and in law in not
appreciating that the advertisement and marketing expenses were
incurred by the appellant wholly and exclusively for the purpose of
its business and were deductible as business expenditure.
4.2.That the assessing officer erred on facts and in law in not
appreciating that the appellant has a long term right to exploit the
trademark `Whirlpool' and benefits arising from the advertisement
and marketing expenditure incurs solely to appellant.
4.3. That the assessing officer erred on facts and in law in not
appreciating that the right allowed by the associated enterprise to
the appellant to use the trademark `Whirlpool' is a privilege and
not a service rendered to the associated enterprise so as to
warrant compensation.
4.4. That the assessing officer erred on facts and in law in not
appreciating that benefit arising to the parent company, if any, is
merely incidental, not warranting disallowance of advertisement
and marketing expenses incurred by the appellant.
5. That the Assessing Officer erred on facts and in law in making
an addition of Rs. 37,72,806 allegedly being undisclosed income
on the basis of difference in the TDS claimed by the appellant and
amount of TDS reported in the individual transaction
statement/AIR information.
6. That the assessing officer erred on facts and in law in allowing
the assessee the claim of double taxation relief u/s 90/91 of the
Act.
The appellant craves leave to add, amend, alter or vary, any of the
aforesaid grounds of appeal before or at the time of hearing of the
appeal."
1.1. Ld.Counsel submitted that all issues are covered by order
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
of this Tribunal in assessee's own case for A.Ys 2010-11 to 2012-
13 vide order dated 18/01/2019.
A.Y. 2013-14
2. Brief facts of the case are as under:
Assessee Company was engaged in the business of
manufacturing and sale of home appliances like Refrigerators,
Washing Machines, Air Conditioners and Microwave Ovens.
Assessee filed its return of income electronically declaring total
income of Rs.1,30,81,76,250/- under normal provisions of the
Act, and income of Rs.1,74,97,67,000/- under section 115JB of
the Act, on 29/11/2013 . The same was processed under section
143(1) of the Act, and subsequently was selected for scrutiny.
Accordingly, notice under section 143(2) of the Act was issued
followed by notices under section 142(1) and questionnaire.
2.1. Ld.AO, during assessment proceedings, observed that
assessee had entered into international transaction with its AE
and since value of such transactions exceeded more than Rs. 15
crores, case was referred to Transfer Pricing Officer (TPO). Ld.TPO
on receipt of reference, issued notice to assessee and called upon
to file documentations prescribed under Rule 10 D of Rules, 1962
and other details as called for.
2.2. Ld.TPO observed that assessee is a subsidiary of Whirlpool
USA, and is engaged in production, sale and distribution of
Whirlpool appliances and that assessee entered into
international transactions and made adjustments. It was
observed that during the year under consideration as in the
earlier year, assessee was engaged in the business of
manufacturing and sale of home appliances like Refrigeraters,
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
Washing Machines, Air Conditioners and Microwave Ovens.
Ld.TPO in his order dated 31.10.2017 observed as under:
" the assessing officer, will accordingly, enhance the income of the
tax payer by Rs.45,57,651/- on substantive basis. The protective
adjustment of Rs.28,71,12,011 has been put on hold awaiting
judgment of the Hon'ble Supreme Court over the concerned issue.
This shall be treated as adjustment u/s 92CA."
Thereafter, upon receipt of such intimation from Ld.TPO, Ld.AO
passed final assessment order by determining the ALP of AMP
expenditure at Rs.42,59,009/-. Ld.AO after considering other
disallowances computed income at Rs.178,31,84,910/-.
3. Aggrieved by order of Ld. AO, assessee is in appeal before us
now.
4. Ground No.1 is general in nature.
Ground No.2 not pressed by Ld.Counsel.
5. Ground No. 3 to 3.21 have been raised against
adjustment made by Ld.AO on account of alleged excessive AMP
expenses amounting to Rs.42,59,009/-. It has been submitted by
Ld. Counsel that said issue now stands squarely covered in
assessee's own case by order of this Tribunal in ITA Nos.
1972/Del/2015 for Assessment Year 2010-11, ITA
No.1787/Del/2016 for A.Y. 2011-12 and ITA No.7085/Del/2017
for A.Y. 2012-13 vide order dated 19/01/2019.
6. We have considered rival contentions of both sides in light
of records and orders passed on this issue by Coordinate
Benches of this Tribunal.
6.1. From records placed before us, it is observed that,
undisputedly Ld.TPO proposed adjustment on account of AMP
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
expenses by applying bright line test. It is observed that Ld.TPO
as well as DRP treated AMP expenses as international transaction
by applying ratio laid down by Special Bench decision of this
Tribunal in case of LG Electronics India Pvt. Ltd., vs. ACIT reported
in (2013) 29 Taxmann.com 300, which stands over ruled by
decision of Hon'ble Delhi High Court in case of Sony Ericson India
Pvt.Ltd vs. CIT reported in (2015) 55 Taxmann.com 240. Hon'ble
Court while deciding Sony Ericson India Pvt.Ltd (supra)
categorically held that bright line test is not an appropriate
yardstick for determining existence of an international
transaction for calculating arm's length price.
6.2. Hon'ble Delhi High Court while deciding question of law
raised for Assessment Year 2008-09 held as under:
"Conclusion
47. For the aforementioned reasons, the Court is of the
view that as far as the present appeals are concerned, the
Revenue has been unable to demonstrate by some tangible
material that there is an international transaction involving
AMP expenses between WOIL and Whirlpool USA. In the
absence of that first step, the question of determining the
ALP of such a transaction does not arise. In any event, in
the absence of a machinery provision it would be
hazardous for any TPO to proceed to determine the ALP of
such a transaction since BLT has been negatived by this
Court as a valid method of determining the existence of an
international transaction and thereafter its ALP.
48. Question (i) in the Assessee's appeal viz., "Was there an
international transaction between WOIL and its AE
involving the AMP expenses within the meaning of Section
92B of the Act read with Section 92F(v) of the Act?" is
answered in the negative, i.e., in favour of the Assessee
and against the Revenue. Consequently Question (ii) in the
Assessee's appeal is not required to be answered. Further,
the only question framed in the Revenue's Appeal viz.,
"Whether the ITAT erred in deleting the addition of Rs.
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
180,73,10,769 made by the AO/TPO on account of AMP
expenses under Section 37 of the Act?" is answered in the
negative, i.e. in favour of the Assessee and against the
Revenue.
49. The impugned order of the ITAT and the corresponding
orders of the DRP and the TPO, on the above issues are
hereby set aside. The appeal of the Assessee, ITA No. 228
of 2015 is allowed and the appeal of the Revenue, ITA No.
610 of 2014 is dismissed in the above terms, but in the
circumstances with no orders as to costs."
6.3. On perusal of orders passed by Ld.TPO/AO/DRP for year
under consideration, it is observed that AMP expenditure has
been considered to be international transaction by applying
bright line test, whereby Ld.TPO proposed an adjustment of Rs.
42,59,009/-.
6.4. Ld.Sr.DR preferred adjournment application on the ground
that issue involved in present appeal is in respect of AMP
adjustment. He submitted that consistent stand has been taken
by revenue before this Tribunal to request for adjournment in all
appeals, where AMP adjustment has been disputed by either
parties on ground that Hon'ble Supreme Court is ceased with the
matter.
6.5. During the course of argument Ld.Sr.DR sought permission
from the Bench to file written submission regarding issues raised
by assessee which was granted. Accordingly, on 10/01/2019 a
detailed written submission has been filed by revenue in respect
of issues raised by assessee for all years under consideration
which is taken on record.
6.6. Plea taken by revenue in written submission to justify AMP
adjustment proposed by Ld.TPO that assessee has been working
for benefit of foreign AE and deserves suitable remuneration.
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
Heavy reliance has been placed by Ld.Sr.DR on BEPS Guidelines,
provided for Transfer Pricing of intangibles, under Action Plan 8-
10 of GE 20/OECD BEPS project in support of adjustment.
6.7. It has further been alleged by Ld.Sr.DR that, there is
mutual agreement/arrangement between assessee and its AE, for
discharge of function of marketing and market development in
addition to agreement/arrangement for sale and distribution of
goods purchased from its AE, for which cost has been borne by
AE. Ld.TPO has also rejected claim that assessee is a full risk
bearing manufacturer/distributor, as there is no supporting
ground for the same.
7. In our considered opinion, since basis on which adjustment
has been made being bright line test itself has been rejected by
Hon'ble Delhi High Court in assessee's own case for Assessment
Year 2008-09, no further interference can be called for at this
stage. Further reliance placed by Ld.Sr.DR on BEPS guidelines
and action plan 8-10 cannot be applied as the same is yet to be
implemented.
7.1. Further it has been submitted by both sides that facts and
circumstances in present appeal are IN no manner different from
that of Assessment Year 2008-09, 2010-11, 2011-12 to 2012-13
that was for consideration before this Tribunal and thereafter
before Hon'ble High Court. In our considered opinion under such
circumstances, no purpose will be served by keeping present
appeal pending, as issues raised by revenue in assessee's own
case along with other cases, have not yet been listed before
Hon'ble Supreme Court. We are therefore inclined to follow view
taken by this Tribunal in assessee's own case which has been
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
upheld by Hon'ble High Court for Assessment Year 2008-09. We
therefore, reject prayer advanced by Ld.Sr.DR for adjournment. It
is observed that similar view has been taken by this Tribunal in
assessee's own case for assessment year 2009-10 in ITA
No.1254/del/2014 vide order dated 26/11/18, and for A.Y.
2010-11, 2011-12, 2012-13 ITA 1972/Del/15, ITA
No.1787/Del/16 & ITA No.7085/Del/17 respectively vide order
dated 18.01.2019.
7.2. However, we appreciate the concern raised by Ld.Sr.DR that
decision of Hon'ble Supreme Court will be binding upon assessee
as well as revenue. We are therefore, inclined to set aside this
issue to Ld.AO/TPO to pass fresh order considering decision of
Hon'ble Supreme Court. Needless to say that proper opportunity
shall be granted to assessee of being heard.
7.3. Accordingly Grounds 3 to 3.21 stand allowed for
statistical purposes.
8. Ground No.4 to 4.3
Ground No. 4 to 4.3 have been raised by assessee regarding
disallowance of expenses under section 37 of the Act, incurred by
assessee on account of alleged advertisement and marketing
expenses.
8.1. Ld.Counsel submitted that this issue has been considered
by Hon'ble High Court assessee's own case which has been
referred to herein above. He submitted that issue relates to AMP
expenses which have been disallowed by Ld.AO under section 37
of the Act. Ld.Counsel submitted that Hon'ble High Court has
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
answered the question in negative that is in favour of assessee
and against revenue.
8.2. Ld.Sr.DR placed reliance upon order of authorities below
and submitted that this issue is interconnected with main issue
of treatment of AMP expenses as international transaction, which
is pending before Hon'ble Supreme Court and the result is
awaited.
8.3. We have perused submissions advanced by both sides in
light of records placed before us.
8.4. As the issue relating to nature of AMP expenses being
international transaction or not, has been set aside to Ld.AO in
preceding paragraphs, allowability of such expenses claimed by
assessee under section 37 of the Act also deserves to be set-
aside. The outcome of this ground raised depends upon decision
of Hon'ble Supreme Court in assessee's own case.
9. Accordingly ground nos. 4 to 4.3 raised by assessee stand
allowed for statistical purposes.
10. Ground no.5 has been raised due to mismatch in 26 A-S. He
submitted that at the time of assessment, all details regarding
claim raised in these grounds were not available with assessee
due to which reconciliation could not be drawn. However
Ld.Counsel submitted that now assessee has all relevant
information to file reconciliation statement in respect of same. He
submitted that these grounds may be set-aside to Ld.AO for due
verification on basis of submissions advanced by assessee.
10.1. Ld.Sr.DR does not object to plea advanced by Ld.
Counsel.
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
10.2. We have perused submissions advanced by both sides
in light of records placed before us.
10.3. Perusal of record it appears that differential amount
reflected in form 26 A-S were not properly reconciled. As now
assessee has all relevant information for the same, in the interest
of natural Justice, we direct Ld. AO to tally database of revenue
in light of details filed by assessee.
10.4. We are therefore inclined to set aside ground no.5 to Ld.AO
for reconciliation and to allow the claim as per law.
10.5. Accordingly Ground No. 5 is allowed for statistical
purposes.
11. Ground no.6 relates to claim of double taxation relief
sought u/s 90-91 of the Act.
11.1. Ld.Counsel submitted that Assessing Officer required
the assessee to furnish the certificate in respect of tax
withheld by foreign group entities. However, since the
assessee was in the process of obtaining the certificates from
the associated enterprises, the same could not be furnished
before the Assessing Officer during the course of assessment
proceedings. The A.O. in the absence of such certificates
disallowed the claim of assessee towards foreign tax credit.
It has been submitted that assessee is now in possession of
all Certificates and can reconcile the payment. Both parties
agreed for issues to be set aside for verification.
11.2. We are therefore inclined to set aside ground no.6 to Ld.AO
for reconciliation and to allow the claim as per law.
11.3. Accordingly Ground No.6 is allowed for statistical
purposes.
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
12. A.Y. 2014-15
Ld.Counsel submitted that all grounds are identical and
similar to that of A.Y. 2013-14.
12.1. Ld.D.R. did not object to the fact submitted by
Ld.Counsel.
12.2. Accordingly, we decide grounds raised in A.Y. 2014-15
in similar manner as A.Y. 2013-14 herein above.
13. In the result appeal filed by assessee for Assessment
Year 2013-14 and 2014-15 stand allowed for statistical
purposes.
Order pronounced in Open Court on .......... February, 2019.
(R.K.PANDA) (BEENA A PILLAI)
ACCOUNTANT MEMBER JUDICIAL MEMBER
Dt. .... February, 2019
Gmv
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
Copy forwarded to: -
1. Appellant
2. Respondent
3. CIT
4. CIT(A)
5. DR, ITAT
- TRUE COPY -
By Order,
ASSISTANT REGISTRAR
ITAT Delhi Benches
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ITA Nos. 8272 & 8273/Del/18 AYs:2013-14 & 2014-15
M/s Whirlpool of India Ltd. Vs. DCIT- LTU
S.No. Details Date
21.02.2019
1 Draft dictated on Dragon
22.02.2019
22.02.19
2 Draft placed before author 25.02.19
Draft proposed & placed before the
3
Second Member
Draft discussed/approved by Second
4
Member
5 Approved Draft comes to the Sr. PS/PS
Kept for pronouncement
6
Order uploaded on :
7 File sent to Bench Clerk
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
17
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