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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 appellant had shown sufficient cause for condonation of the delay in filing the appeal and whether the appeal was liable to be dismissed as time-barred.
Analysis: The appeal was required to be filed within the prescribed limitation period under the governing foreign exchange statute, with a limited power to entertain it beyond that period only on proof of sufficient cause. On the material placed, the appellant did not state with certainty when the adjudication order was received, did not explain the actual length of delay, and failed to furnish a satisfactory basis for the late filing. The Tribunal relied on the documentary material produced by the respondent and found that the order had been served much earlier, making the delay ex facie inordinate and unexplained.
Conclusion: The appellant failed to establish sufficient cause for condonation of delay, and the appeal was held to be time-barred.
Ratio Decidendi: Condonation of delay in filing an appeal can be granted only on proof of sufficient cause, and an inordinate, unexplained delay beyond the statutory period renders the appeal liable to dismissal as time-barred.