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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 challenge to Section 72(c) of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 had been raised in the criminal petition; and whether the impugned High Court observation holding that the provision offended Article 20 of the Constitution of India should remain stayed pending consideration of interim relief.
Analysis: The order records that no challenge to the validity of Section 72(c) was raised in the criminal petition. It also notices the High Court's observation that criminal liability under the provision was said to be inconsistent with Article 20 of the Constitution of India. On that basis, notice was issued on the prayer for interim relief and the impugned portion was directed to remain stayed.
Outcome: Interim notice was issued and the impugned observation was stayed. No final adjudication on the validity of Section 72(c) was rendered.