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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 drawback refund applications filed beyond the prescribed period could be entertained by condoning delay under Rule 6 of the Customs and Central Excise Duties Drawback Rules, 1971, and whether relief could be granted by invoking Rule 15 of those Rules.
Analysis: Rule 6(1)(a) permits an application for drawback within thirty days from the date of export, with a further period of thirty days available only if sufficient cause is shown. The Court held that this limited condonation power operates only within the statutory grace period and does not extend beyond sixty days from export. The applications in question were filed well beyond that period. The Court further held that Rule 15 is a distinct provision dealing with relaxation or exemption from compliance with the Rules, and it is not the same as condonation of delay under Rule 6. Since the petitioners had never properly sought relaxation under Rule 15 before the authorities, they could not obtain such relief through the writ proceedings.
Conclusion: The drawback claims were rightly rejected as time-barred, and no relief could be granted by treating the belated applications as capable of condonation under Rule 6 or by substituting a Rule 15 request.