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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. 
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Issues: Whether the inordinate delay of nearly five years in filing the appeal was explained so as to warrant condonation.
Analysis: The application for condonation rested on the assertion that the order-in-original was received only with the recovery notice in January 2001. The record showed that the proceedings were contested on merits, the show cause notice had been replied to, and no convincing material was produced to show that the order had not been received earlier. The affidavit filed in support was found vague. The burden to show sufficient cause for the extraordinary delay lay on the appellant, and no substantial cause was established. Mere lapse of time and a general plea of non-receipt were insufficient to defeat the respondent's accrued right to rely on the order.
Conclusion: The delay was not liable to be condoned, and the appeal was therefore time-barred.
Ratio Decidendi: For condonation of long delay, the applicant must affirmatively establish sufficient cause with credible material; an unexplained and inordinate delay cannot be condoned on a bare assertion of non-receipt of the order.