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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 silver palladium wire containing 70% silver and 30% palladium was classifiable under sub-heading 7101.60 as silver wire or under sub-heading 7101.90 as an alloy of platinum.
Analysis: Note 3(b) to Chapter 71 treats palladium as platinum for the purpose of that chapter. Note 4 then provides that an alloy containing 2% or more by weight of platinum is to be treated as an alloy of platinum, while clause (c) applies only to other alloys not covered by clauses (a) and (b). Since the product contained 30% palladium, it satisfied the platinum threshold through the chapter note deeming provision. The fact that silver predominated by weight did not take the product outside clause (a), and clause (c) could not be invoked because it is residuary in nature. The classification therefore followed the chapter notes rather than the mere predominance of silver.
Conclusion: The product was correctly classifiable under sub-heading 7101.90 as an alloy of platinum, and the appeal failed.
Ratio Decidendi: For classification under Chapter 71, a chapter note deeming palladium to be platinum prevails, and an alloy containing 2% or more of such deemed platinum is classifiable as an alloy of platinum; the predominance of silver by weight does not control where the chapter notes apply.