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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, after a dealer's assessment case for a particular year had been transferred by the Commissioner from one Sales Tax Officer to another, the transferee Sales Tax Officer alone had jurisdiction to initiate and complete reassessment proceedings for escaped turnover under section 21, or whether the original Sales Tax Officer could still assume such jurisdiction.
Analysis: The transfer order under rule 81 of the U.P. Sales Tax Rules shifted the assessment case to the transferee officer without any limitation confining it to the original assessment only. A proceeding under section 21 for escaped turnover is in substance a reassessment of the same year's liability and forms part of the assessment case. Once the case was transferred, the transferee became the assessing authority for all purposes in relation to that year, including reopening the assessment and reassessing escaped turnover.
Conclusion: Jurisdiction to proceed under section 21 vested in the transferee Sales Tax Officer and not in the original Sales Tax Officer; the assessee's contention succeeded.