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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: (i) Whether the orders passed under Vera Samadhan Yojna, 2019 were illegal for not granting the benefit of the scheme in full and for ignoring the later certificate produced in support of the 'C' forms. (ii) Whether the rejection of the rectification application suffered from an error apparent on the face of the record.
Issue (i): Whether the orders passed under Vera Samadhan Yojna, 2019 were illegal for not granting the benefit of the scheme in full and for ignoring the later certificate produced in support of the 'C' forms.
Analysis: The scheme required pending appeals to be processed within the stipulated timetable, with details of 'C' forms to be furnished by the prescribed date and their genuineness to be verified from the prescribed sources. The appellate authority had already verified the available material and passed the order within the outer limit fixed by the scheme. The later certificate dated 17.02.2020 was produced after the cut-off date and could not be used to enlarge the benefit of the scheme beyond the prescribed time frame.
Conclusion: The challenge to the partial grant of benefit under the scheme fails and the order dated 15.02.2020 is sustained.
Issue (ii): Whether the rejection of the rectification application suffered from an error apparent on the face of the record.
Analysis: Rectification was available only for a patent mistake apparent from the record. Since the authority had already considered the material permitted under the scheme and the grievance essentially sought reconsideration on the basis of a subsequent document, no apparent error was shown. The authority was therefore justified in refusing rectification.
Conclusion: The rejection of the rectification application is upheld.
Final Conclusion: The writ petitions fail because the impugned orders were passed in accordance with the time-bound scheme and no rectifiable error was demonstrated.
Ratio Decidendi: A time-bound amnesty scheme must be applied strictly according to its prescribed cut-off dates and verification mechanism, and a later-produced document cannot be relied upon to extend the scheme's benefit or to create an error apparent warranting rectification.