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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 reliefs and concessions under clause 8 of page 7 of the Modified Scheme were available only during electrical breakdowns or for the entire rehabilitation period.
Analysis: The Scheme was framed for revival of the industrial unit and its language, read with the surrounding clauses and the Board's subsequent directions, showed that the concession was linked to the rehabilitation period. The expression "break-down/rehabilitation" could not be read narrowly to confine the benefit only to electrical breakdowns, particularly when other clauses expressly referred to the rehabilitation period and the Board's later order reiterated that the concession was not restricted to breakdown periods. The Court also noted that the Note Sheet and later BIFR order supported the broader interpretation.
Conclusion: The issue was decided in favour of the petitioners. The reliefs and concessions under clause 8 were held to apply for the entire rehabilitation period.
Ratio Decidendi: A rehabilitation-related concession in a sanctioned scheme must be construed in the context of the scheme as a whole, and where the language and subsequent authoritative clarification show that the benefit extends through the rehabilitation period, it cannot be restricted to isolated breakdown periods by a narrow literal reading.