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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 departmental appeal was liable to be rejected for non-compliance with the prescribed appellate procedure, including absence of properly set out grounds of appeal and want of proof of authorization under the governing provision.
Analysis: The appeal papers did not contain grounds of appeal in the manner required by the procedural rules, and the Tribunal declined to treat an annexure reference as a substitute for distinct, consecutively numbered grounds. The record also did not show any authorization empowering the officer who filed the appeal to act on behalf of the Collector as required by the statutory provision governing departmental appeals. Since the filing requirements were mandatory and had not been complied with, the appeal could not be entertained.
Conclusion: The appeal was not maintainable and was rejected for non-compliance with the statutory provision and the procedural rules.
Ratio Decidendi: A departmental appeal must comply strictly with the statutory requirement of authorization and the prescribed rule requiring proper grounds of appeal; failure to do so renders the appeal liable to rejection.