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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 valuation of supply of second-hand gold jewellery purchased from unregistered persons and sold without change in the nature of the goods is to be determined under Rule 32(5) of the Central Goods and Services Tax Rules, 2017.
Analysis: Rule 32(5) applies where a taxable supply is made by a person dealing in buying and selling of second-hand goods, the goods are used as such or after only minor processing not changing their nature, and no input tax credit has been availed on the purchase. The supply of second-hand jewellery was treated as a taxable supply, and the applicant accepted that the goods were purchased from unregistered persons, no input tax credit was claimed, and the jewellery was sold in the same form after only cleaning and polishing without altering its nature or form. These facts satisfied the conditions for application of the special valuation method under the rule.
Conclusion: The valuation of supply is to be made under Rule 32(5) of the Central Goods and Services Tax Rules, 2017, and GST is payable only on the difference between the selling price and the purchase price, subject to the rule's terms.