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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 could be admitted by condoning the delay on the ground that later admission of connected civil appeals by the Supreme Court showed that the issue was still open.
Analysis: The delay was not attributable to any slow or bureaucratic movement of the file. The order in appeal had initially been accepted, and the appeal was filed only after the department noticed that related matters had been admitted before the Supreme Court. The governing test remained whether sufficient cause existed for not presenting the appeal within the prescribed period. A circumstance arising after the period of limitation had expired could not, by itself, constitute sufficient cause. The cited precedents also supported the view that a later change or clarification in legal position does not justify revival of a time-barred appeal.
Conclusion: The department failed to show sufficient cause for the delay, so the condonation request was rejected and the appeal was dismissed.