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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 departmental appeal was maintainable in view of the CBDT monetary limit for filing appeals before the Income Tax Appellate Tribunal.
Analysis: The appeal was tested against the revised monetary limit prescribed by the CBDT through Circular No. 17 of 2019, which enhanced the limit for appeals before the Tribunal to Rs. 50,00,000. The tax effect in the present appeal was found to be below that threshold. In such circumstances, the departmental appeal was not maintainable, subject to the stated exceptions in the circular.
Conclusion: The appeal was held to be not maintainable on account of low tax effect and was dismissed.
Final Conclusion: The departmental challenge could not be entertained because the disputed tax effect did not cross the revised monetary threshold fixed for appeals before the Tribunal.
Ratio Decidendi: A departmental appeal is not maintainable where the tax effect is below the applicable monetary limit prescribed by the CBDT, unless the case falls within a recognised exception.