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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 authority rightly treated the State's response as deemed consent under the rehabilitation framework and whether the impugned order called for interference in supervisory jurisdiction.
Analysis: The scheme had been circulated for consent and the State's response was received after the stipulated period. The Court held that where no consent is received within the prescribed period, deemed consent follows under the statutory scheme. The later letters raising further objections were treated as belated and could not undo the earlier position. The Court also held that the authority had no power to review its own final order, and a request styled as clarification was in substance an impermissible review. In supervisory jurisdiction, interference was not warranted absent perversity, jurisdictional error, or an error apparent on the face of the record. The rehabilitation scheme had already been acted upon and the balance of equities did not justify disruption.
Conclusion: The challenge failed. The deemed consent finding and refusal to entertain review or clarification were upheld, and no interference with the rehabilitation scheme was called for.
Ratio Decidendi: Under a statutory rehabilitation scheme, failure to respond within the prescribed period results in deemed consent, and a tribunal lacking review power cannot reopen its final order merely because a party later seeks clarification in substance.