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AI Drafter

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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        Case ID :

        I-T fast-tracks disposal of high value litigations

        July 11, 2017

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        New Delhi, Jul 11 (PTI) With ₹ 7.3 lakh crore locked in litigations, the tax department has set December 31 as the deadline for deciding all appeals involving demands of ₹ 50 crore and above, according to its new action plan.

        As on April 1, there were 1,390 appeals involving demands of ₹ 50 crore and above, aggregating to ₹ 4.26 lakh crore.

        The tax department wants these demands, about 70 per cent of the amount locked in litigations, to be settled by the year end.

        The Central Action Plan 2017-18 of the Central Board of Direct Taxes (CBDT) has linked performance evaluation of taxmen with the disposal of appeals against tax demands.

        "To meet the core objectives of budget collection, reduction in outstanding demand and litigation management, a two-pronged strategy shall be adopted with proportionate focus on optimising disposal in terms of numbers and on maximising disposal of appeals involving high quantum of demand," it said.

        The plan categorises appeals against tax demands by value with priority being placed on disposal of appeals involving ₹ 10 lakhs and above. Within this, cases involving ₹ 50 crore and more have to be given higher priority.

        The next priority has been given to disposing appeals involving demand of less than ₹ 10 lakh, but which had been filed up to March 31, 2017.

        The lowest priority has been given to demands of less than ₹ 10 lakhs and filed during current fiscal.

        The Action Plan sets Commissioner of Income Tax (CIT) a target for disposal of at least 30 per cent of the appeals involving demand of ₹ 10 lakhs and above; and 100 per cent of appeals pending as on April 1, 2017 that involve demand of ₹ 50 crore and above.

        Also at least 70 per cent of appeals that involve demand of less than ₹ 10 lakhs have to be disposed of.

        "The above targets should result, on all-India basis, in an aggregate disposal of about 1.63 lakh appeals, which is expected to significantly reduce the pendency at the end of the year as compared to the pendency as on April 1, 2017, as well as unlock demand of about ₹ 4.5 lakh crore," the Action Plan document said.

        The targets of disposal of 30 per cent of appeals involving demand of ₹ 10 lakh and above and 70 per cent of appeals involving demand less than ₹ 10 lakhs, must be achieved by each CIT(A) and in the Principal CCIT region as a whole.

        "For the purpose of evaluation of performance of an individual officer holding additional appellate charge(s) during the year/part-year, the aggregate disposal including in the additional charge(s) held, shall be considered," the document said.

        As of April 1, 2017, over 2.90 lakh appeals are pending with CsIT(A) involving demand of ₹ 6.11 lakh crore. Besides, total tax demand stayed by ITAT/Courts stood at ₹ 1.18 lakh crore.

        The Action Plan also entrusted the Chief Commissioner Income Tax (CCIT) to identify 20 top litigation cases of assesses in his region by July 31, based on importance of issues, revenue potential and recurring nature of the issue.

        After identification, the cases with common or similar issues shall be bunched and the Principal CCIT would then nominate a resource person (of the level of Principal CIT/CIT) or form a team for each case or bunch of cases by August 15.

        Fast track tax litigation: CBDT action plan mandates prioritized disposal and links officer performance to appeal outcomes. The CBDT Action Plan directs a fast track disposal regime for tax appeals, prioritising high value cases and linking performance evaluation of tax officers to achievement of prescribed disposal targets; regional heads must identify, bunch and allocate resource persons or teams to top litigation matters to reduce pendency and unlock outstanding demand.
                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.

                                Fast track tax litigation: CBDT action plan mandates prioritized disposal and links officer performance to appeal outcomes.

                                The CBDT Action Plan directs a fast track disposal regime for tax appeals, prioritising high value cases and linking performance evaluation of tax officers to achievement of prescribed disposal targets; regional heads must identify, bunch and allocate resource persons or teams to top litigation matters to reduce pendency and unlock outstanding demand.





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                                ActsIncome Tax
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