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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 assessment of property tax could be sustained despite non-publication of notices under Sections 218, 219 and 220(1) of the Act, and whether such non-compliance could be cured under Section 684 of the Act.
Analysis: The statutory scheme treats fixation of annual rental value under Section 212 and the Rules as distinct from the later stage of assessment under Sections 214 to 224. Once the assessment book is prepared, public notice under Section 218, inspection under Section 219, and notice inviting objections under Section 220(1) form a connected and mandatory sequence before the assessment book can be authenticated under Section 224. Special notice under Section 220(2) is only an additional step and cannot replace the earlier publication requirements. In taxation, the provisions must be strictly complied with, since Article 265 requires levy and collection only under authority of law. Section 684 is confined to informalities, clerical errors and minor defects, and cannot validate an absolute failure to follow mandatory notice provisions that go to the root of the assessment process.
Conclusion: Non-compliance with Sections 218, 219 and 220(1) vitiated the assessments, and Section 684 did not cure the defect.
Ratio Decidendi: Where a tax statute prescribes a mandatory sequence of notice, inspection and objection before assessment attains finality, strict compliance is essential and a complete failure to follow that sequence cannot be treated as a curable irregularity.