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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, for claiming exemption under the relevant notifications, the percentage of indigenous cotton seed oil had to be computed only with reference to the vegetable products manufactured using that oil, or with reference to all vegetable products and margarine cleared from the factory during the quarter.
Analysis: The notifications made exemption available only in respect of those vegetable products manufactured using indigenous cotton seed oil and cleared in the relevant quarter. The expressions used in the notifications pointed to the vegetable products actually manufactured with cotton seed oil, and the prescribed account form also supported that construction. The extent of exemption depended on the percentage by weight of cotton seed oil used in relation to the total weight of such products, not on the total output of all products manufactured during the quarter, including products in which no cotton seed oil was used.
Conclusion: The computation had to be confined to the vegetable products manufactured using indigenous cotton seed oil, and the assessee's wider method of computation was correct.
Ratio Decidendi: An exemption notification tied to the use of a specified input must be computed only with reference to the goods manufactured with that input and not with reference to unrelated goods cleared during the same period.