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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 delay of 514 days in filing the application under Section 34 of the Arbitration and Conciliation Act, 1996 could be condoned by applying Sections 5 and 14 of the Limitation Act, 1963, despite the limit prescribed by Section 34(3) of the 1996 Act.
Analysis: Section 34(3) permits an application to set aside an arbitral award only within three months from receipt of the award, with a further extension of thirty days on sufficient cause being shown, and the words "but not thereafter" exclude any further enlargement of time. Section 5 of the Limitation Act has no application to an application under Section 34, because the statutory scheme makes the limitation under Section 34 absolute beyond the additional thirty days. Section 14 of the Limitation Act can exclude time spent bona fide before a court without jurisdiction, but even after giving that benefit, the respondent still remained beyond the outer statutory limit by 131 days, and administrative difficulties could not justify condonation beyond the period permitted by Section 34(3).
Conclusion: The delay beyond the statutory ceiling could not be condoned, and the application under Section 34 was barred by limitation.
Ratio Decidendi: Where Section 34(3) of the Arbitration and Conciliation Act, 1996 prescribes a fixed limitation period with a further extension of only thirty days and uses the expression "but not thereafter", courts cannot condone delay beyond that outer limit, though Section 14 of the Limitation Act, 1963 may be applied only to exclude bona fide time spent in a court without jurisdiction.