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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 addition of accrued interest on loans classified as non-performing assets was liable to be sustained in the light of section 43D of the Income-tax Act, 1961.
Analysis: The issue raised in the appeal was identical to an earlier appeal already decided by the Court in favour of the assessee. The parties agreed that the controversy was the same, and the earlier decision governed the present matter.
Conclusion: The appeal by the Revenue was dismissed and the addition was not sustained.
Final Conclusion: The substantive question stood concluded against the Revenue in view of the prior binding decision on the same issue, resulting in dismissal of the appeal.
Ratio Decidendi: Where the same question of law concerning accrual taxation of interest on non-performing assets has already been answered in favour of the assessee, a later appeal on the identical issue is liable to be dismissed.