Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI • Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions • Judicial precedents and Supreme Court, High Court and other citations • Issue-wise legal analysis • Practical arguments and supporting content • Professionally structured draft ready for further review.
Associated enterprises adjustment: arm's-length profit allocation can be included for taxation and other State must make corresponding tax adjustment. Article 9 permits reallocation and inclusion in taxable profits where enterprises of the Contracting States are associated through management, control or capital and conditions between them differ from those between independent enterprises; profits that would have accrued but for those conditions may be taxed accordingly. If one State includes and taxes such reallocated profits that have also been taxed in the other State, that other State shall make an appropriate adjustment to its tax on those profits, with due regard to the Agreement and consultation between competent authorities.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Associated enterprises adjustment: arm's-length profit allocation can be included for taxation and other State must make corresponding tax adjustment.
Article 9 permits reallocation and inclusion in taxable profits where enterprises of the Contracting States are associated through management, control or capital and conditions between them differ from those between independent enterprises; profits that would have accrued but for those conditions may be taxed accordingly. If one State includes and taxes such reallocated profits that have also been taxed in the other State, that other State shall make an appropriate adjustment to its tax on those profits, with due regard to the Agreement and consultation between competent authorities.
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