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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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2018 (4) TMI 94

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.... respondent (by Sri. Sandeep Huilgol, Advocate)   JUDGEMENT The learned counsel Mr. Sandeep Huilgol undertakes to file power for the respondent. The Revenue seeks to maintain this appeal under Section 260-A of the Income Tax Act, 1961 ['the Act'] against the order dated 15.03.2017, as passed by the Income Tax Appellate Tribunal, Bench 'B', Bengaluru ['the Tribunal'] in M.P. No.28/Ba....

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....d the contention of the assessee that the said expenditure incurred in foreign currency and the telecommunication charges should also be reduced from the total turnover for the purpose of computation of relief under Section 10-A of the Act. It appears that while initially deciding the appeal filed by the assessee [IT(TP) A. No.1236/Bang/2010] by the order dated 09.12.2016, the Tribunal dealt wi....

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.... that had been reduced from export turnover, to be also reduced from the total turnover, since nothing in Section 10-A of the Act provides for such an exclusion. Having heard the learned counsel for the appellant s and having examined the record with reference to the la w applicable, we are satisfied that no substantial question of law is involved and this appeal does not merit admission. Th....

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....not be different. Therefore, though there is no definition of the term 'total turnover' in Section 10-A, there is nothing in the said Section to mandate that, what is excluded from the numerator that is export turnover would nevertheless form part of the denominator. Though when a particular word is not defined by the legislature and an ordinary meaning is to be attributed to the same, the s....