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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 metallising of polyester/polyester films amounts to manufacture liable to central excise duty.
Analysis: The appeal was pressed only on the question whether metallising of polyester/polyester films constituted manufacture. The Tribunal followed its earlier decision holding that metallising or lacquering of films does not amount to manufacture for the purposes of Section 2(f) of the Central Excises and Salt Act, 1944.
Conclusion: Metallising of polyester/polyester films does not amount to manufacture and is not liable to duty; the impugned order was set aside and the appeal was allowed with consequential relief.