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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 Revenue appeals were liable to be dismissed on the ground that the tax effect was below the monetary limit prescribed for filing appeals before the Tribunal.
Analysis: The appeals involved tax effect below the prescribed threshold under the applicable instruction fixing the monetary limit for departmental appeals. The instruction was treated as applicable to pending appeals as well, consistent with the view taken in the cited High Court decision and the subsequent clarification issued by the Board. In consequence, the appeals could not be entertained on merits.
Conclusion: The appeals were not maintainable in view of the monetary limit and were dismissed.
Final Conclusion: The departmental appeals stood rejected solely because the tax effect was below the prescribed limit, and no adjudication on the substantive dispute was undertaken.
Ratio Decidendi: A departmental appeal is not maintainable where the tax effect is below the monetary limit prescribed by the applicable administrative instruction, and such instruction applies to pending appeals also.