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AI Drafter

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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        Case ID :

        2019 (7) TMI 235 - SC - Income Tax

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        Petitioner given final chance to deposit Rs. 5 crores with Income Tax authorities The court granted the petitioner a final opportunity to deposit Rs. 5 crores with the Principal Commissioner, Income Tax, Chennai within six weeks to ...
                        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                          Provisions expressly mentioned in the judgment/order text.

                              Petitioner given final chance to deposit Rs. 5 crores with Income Tax authorities

                              The court granted the petitioner a final opportunity to deposit Rs. 5 crores with the Principal Commissioner, Income Tax, Chennai within six weeks to address outstanding dues. Failure to comply would result in petition dismissal due to the petitioner's lack of concrete steps in resolving financial obligations despite previous leniency and attachment releases. The court emphasized timely compliance and proactive measures, scheduling a follow-up hearing to review adherence to the payment deadline and determine further actions.




                              Issues:
                              1. Petitioner's request for lifting attachment on properties.
                              2. Failure of the petitioner to take concrete steps to resolve the matter.
                              3. Granting a final opportunity to the petitioner to deposit a specific sum.

                              Issue 1: Petitioner's request for lifting attachment on properties

                              The petitioner submitted that a demand of Rs. 9,33,16,434 was made by the department, with properties worth over Rs. 40 crores under attachment. The court allowed the petitioner to appear before the Principal Commissioner, Income Tax, Chennai, with documents showing properties worth more than Rs. 9.33 crores as security, unencumbered, and the option to deposit cash as security. If satisfied, the Principal Commissioner could lift the attachment on other properties to facilitate payment as per the High Court's order. Subsequently, one property's attachment was lifted, and three accounts were released, expecting the petitioner to pay a reasonable amount. However, the petitioner failed to take concrete steps, leading to the court granting a final opportunity.

                              Issue 2: Failure of the petitioner to take concrete steps to resolve the matter

                              Despite the court's leniency and the lifting of attachments on certain properties and accounts, the petitioner did not show substantial progress in resolving the outstanding dues. As a final chance, the court granted the petitioner six weeks to deposit Rs. 5 crores with the Principal Commissioner, Income Tax, Chennai. Failure to comply with this directive would result in the dismissal of the petition. This decision was made due to the lack of proactive measures on the petitioner's part to address the financial obligations as per the court's previous orders.

                              Issue 3: Granting a final opportunity to the petitioner to deposit a specific sum

                              In light of the petitioner's inaction and failure to make significant payments towards the outstanding demand, the court issued a final ultimatum. The petitioner was given a strict deadline of six weeks to deposit Rs. 5 crores with the Principal Commissioner, Income Tax, Chennai. This deadline was set to ensure the petitioner's compliance with the court's directives and to expedite the resolution of the financial liabilities. The court scheduled a follow-up hearing on 19.8.2019 to review the petitioner's adherence to the payment deadline and determine further actions based on the outcome.

                              This detailed analysis of the judgment highlights the court's progressive approach in addressing the petitioner's financial obligations while emphasizing the importance of timely compliance and proactive measures in resolving legal disputes.
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                              Note: It is a system-generated summary and is for quick reference only.

                              Topics

                              ActsIncome Tax
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