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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: (i) Whether sales of coarse and medium cloth were exempt from State sales tax by reason of Article 286(3) of the Constitution and the Parliamentary declaration of essential goods; (ii) Whether Explanation (2) to section 2(k) of the Hyderabad General Sales Tax Act, 1950 excluded such sales from the meaning of "sale" so as to prevent taxation.
Issue (i): Whether sales of coarse and medium cloth were exempt from State sales tax by reason of Article 286(3) of the Constitution and the Parliamentary declaration of essential goods.
Analysis: Article 286(3) restricted a State law enacted after a Parliamentary declaration of essential goods from imposing tax on sales or purchases of such goods. The Hyderabad General Sales Tax Act, 1950, as amended in 1952, was enacted before the Parliamentary Act declaring coarse and medium cloth to be essential goods. The constitutional restriction therefore did not invalidate the pre-existing State law or its amendment. The argument based on the earlier Essential Supplies legislation was not pressed and in any event did not assist the appellants.
Conclusion: The sales were not exempt under Article 286(3), and this contention failed.
Issue (ii): Whether Explanation (2) to section 2(k) of the Hyderabad General Sales Tax Act, 1950 excluded such sales from the meaning of "sale" so as to prevent taxation.
Analysis: The explanation applied only to transfers of goods in respect of which no tax could be imposed by reason of Article 286 of the Constitution. Since Article 286(3) only barred State laws made after the Parliamentary declaration, and no such later State law taxed these goods, the explanation did not operate to exclude the transfers of coarse and medium cloth from the statutory definition of sale. The State Act therefore continued to apply.
Conclusion: The explanation did not exempt the transactions from tax, and this contention failed.
Final Conclusion: The constitutional and statutory objections to the levy were rejected, and the sales tax assessments were upheld.
Ratio Decidendi: Article 286(3) disables only a State law made after a Parliamentary declaration of essential goods from imposing tax on such goods, and an interpretative provision tying exemption to Article 286 cannot extend that immunity beyond the constitutional limit.