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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 demand of differential excise duty denying SSI exemption was barred by limitation.
Analysis: The demand arose from denial of SSI exemption on the ground that the amalgamation of the units had taken effect from an earlier date. The amalgamation order and the relevant facts had been brought to the department's knowledge, and the show cause notice did not allege suppression of facts or misdeclaration with intent to evade duty. In these circumstances, invocation of the extended period was not sustainable.
Conclusion: The demand was barred by limitation and could not be sustained.