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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 questions of law raised by the Revenue were already covered against it by prior decisions of the Court. (ii) Whether the appeal deserved interference in view of the binding precedents.
Issue (i): Whether the questions of law raised by the Revenue were already covered against it by prior decisions of the Court.
Analysis: The respondent pointed out that the first question of law stood covered by an earlier decision in the assessee's own case, and the second question was covered by later decisions of the Court. The Revenue did not dispute that position.
Conclusion: The questions of law were covered against the Revenue and in favour of the assessee.
Issue (ii): Whether the appeal deserved interference in view of the binding precedents.
Analysis: Once the issues raised were found to be governed by prior binding decisions, no further consideration on merits was warranted.
Conclusion: The appeal did not merit interference.
Final Conclusion: The Revenue's appeal was dismissed and the questions of law were answered in favour of the assessee and against the Revenue.
Ratio Decidendi: Where the substantial questions of law raised in an income-tax appeal are covered by binding precedent, the appeal is liable to be dismissed and the questions answered accordingly.