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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: (i) Whether a guide map publication containing descriptive material, tourist information, routes and related contents was a "reading book" eligible for exemption under Entry 22. (ii) Whether the Tribunal could entertain for the first time a turnover item not raised before the Appellate Assistant Commissioner.
Issue (i): Whether a guide map publication containing descriptive material, tourist information, routes and related contents was a "reading book" eligible for exemption under Entry 22.
Analysis: Entry 22 exempted sales of books and was later expanded to "sales of reading books including text-books". The publication in question was not a mere map sheet but contained substantial descriptive matter about the city, its history, places of interest, postal zones, bus routes and other information useful to a reader or tourist. A publication with such contents answers the description of a book meant for reading.
Conclusion: The publication was a reading book and its turnover was entitled to exemption in favour of the assessee.
Issue (ii): Whether the Tribunal could entertain for the first time a turnover item not raised before the Appellate Assistant Commissioner.
Analysis: The item of Rs. 11,650 had not been put in issue before the Appellate Assistant Commissioner. Following the governing appellate principle applied by the Court, a point not agitated at that stage could not be raised before the Tribunal for the first time.
Conclusion: The Tribunal ought not to have considered the item of Rs. 11,650 and the assessee's challenge succeeded on this point.
Final Conclusion: The revision succeeded on both the exemption issue and the procedural issue, resulting in a partial allowance of the petition in favour of the assessee.
Ratio Decidendi: A publication is eligible as a "reading book" if its contents are meant to be read and provide substantive material for reading, and a new turnover item cannot ordinarily be introduced before the Tribunal for the first time when it was not raised before the lower appellate authority.