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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 petitioners were entitled to interest on the amounts deposited with the appropriate authority under Chapter XXC of the Income-tax Act, 1961 and whether refusal to release such interest was justified.
Analysis: The statutory scheme required the consideration amount payable on purchase of the immovable property to be tendered within the prescribed period. Where the amount was retained by the appropriate authority and invested in fixed deposits, Section 269UG(4) empowered the authority to invest the deposited consideration and direct the interest or other proceeds to be paid in a manner giving the interested parties the same benefits as they would have derived from the property. The principal amounts belonged to the petitioners, and interest accrued on those amounts while retained by the authority. Refusal to release the interest merely because no court direction had been obtained at the time of withdrawal of the earlier writ petitions was held to be unjustified.
Conclusion: The petitioners were entitled to the interest accrued on the deposited amounts, and the appropriate authority was bound to release the interest to them.
Ratio Decidendi: Where consideration money belonging to a transferor is retained and invested by the appropriate authority under Chapter XXC, the authority must apply Section 269UG(4) fairly and cannot appropriate the accrued interest to itself merely because no express court direction for payment of interest was made.