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.
High Court allows review applications post Supreme Court ruling granting Assessee 100% deduction under Section 80IC. The High Court allowed the review applications based on the subsequent Supreme Court decision in M/s AARHAM Softronics, holding that the Assessee is ...
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Provisions expressly mentioned in the judgment/order text.
High Court allows review applications post Supreme Court ruling granting Assessee 100% deduction under Section 80IC.
The High Court allowed the review applications based on the subsequent Supreme Court decision in M/s AARHAM Softronics, holding that the Assessee is entitled to claim 100% deduction under Section 80IC for the relevant assessment years. The judgment clarified that the questions regarding the deduction under Section 80IC for the assessment years in question are answered in favor of the Assessee and against the Revenue. The remaining part of the original judgment was maintained, and any pending applications were disposed of accordingly.
Issues: Review of order based on subsequent Supreme Court decision on a question of law regarding deduction under Section 80IC of the Income Tax Act.
Analysis: The judgment dealt with two review applications concerning the admissibility of deduction under Section 80IC of the Income Tax Act, 1961. The questions of law regarding substantial expansion and the initial assessment year were decided against the Assessee in a previous order dated 06.09.2018. The Assessee filed a review application under Order 47 Rule 1 and 2 of the Code of Civil Procedure, citing a subsequent Supreme Court decision in Pr. Commissioner of Income Tax, Shimla Vs. M/s AARHAM Softronics 2019 (412) ITR 623. The Revenue contended that a review cannot be based on a superior court's decision reversing or modifying a question of law. However, the High Court noted that the original judgment was based on a Supreme Court decision in M/s Classic Binding Industries, which was subsequently clarified in M/s AARHAM Softronics by the Supreme Court. The High Court found it in the interest of justice to allow the review application to avoid multiplicity of litigation.
The High Court allowed the review applications based on the subsequent Supreme Court decision in M/s AARHAM Softronics, holding that the Assessee is entitled to claim 100% deduction under Section 80IC for the relevant assessment years. The judgment clarified that the questions regarding the deduction under Section 80IC for the assessment years in question are answered in favor of the Assessee and against the Revenue. The remaining part of the original judgment was maintained, and any pending applications were disposed of accordingly.
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