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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 proceedings initiated under section 21 of the U.P. Sales Tax Act on the basis of information already available with the sales tax authority were without jurisdiction.
Analysis: The Tribunal found that the notice under section 21 was issued only to verify information already in the possession of the Sales Tax Officer, that the information related to another party and not to the assessee, and that no other material was shown to justify the initiation of proceedings. In such circumstances, and following the settled view that section 21 cannot be invoked merely for verification of information already available with the department, the initiation of proceedings was held to be legally unsustainable.
Conclusion: The initiation of proceedings under section 21 was without jurisdiction and the revision failed.