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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 notice issued for revision under Section 263 of the Income-tax Act, 1961 was barred by limitation.
Analysis: The order sought to be revised was dated 31.03.2017, while the notice invoking revisionary powers was issued on 01.02.2023. Section 263(2) permits an order under Section 263 only within two years from the end of the financial year in which the order sought to be revised was passed. On the admitted dates, the impugned notice was issued well beyond the prescribed period.
Conclusion: The notice was barred by limitation and was liable to be set aside.