Just a moment...
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. 
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
Press 'Enter' after typing page number.
Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
Press 'Enter' after typing page number.
Press 'Enter' after typing page number.
Don't have an account? Register Here
Press 'Enter' after typing page number.
Issues: Whether the appellant had made out a prima facie case for waiver of predeposit on the exemption issue and the valuation issue.
Analysis: The product was treated as falling within the wafer category, and wafers were recognised as biscuits. On that basis, denial of exemption under Notification No. 3/2006-CE was not justified at the interim stage. On valuation also, the appellant showed a prima facie case by pointing to the same duty payment pattern followed by the principal manufacturer.
Conclusion: The appellant established a prima facie case on both issues, warranting waiver of predeposit and grant of stay during pendency of the appeals.