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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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2019 (11) TMI 312

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.... the Learned Single Judge of this Court in W.P.Nos.25239, 25241, 25242, 25244, 25245 & 25248 of 2019. 2.By the impugned common order, the Learned Single Judge has dismissed the above Writ Petitions which were directed against six Notices all dated 29.03.2019 issued under Section 148 of the Income Tax Act, 1961 for the Assessment Years of 2012-13 to 2017-2018 to the appellant. 3.By the impugned common order, the learned single judge has dismissed the six writ petitions with the following observations:- 23. This Court is of the considered view that such 11th hour petitions will derail assessments process under fiscal law statues. It is made clear that this view is taken in the peculiar trajectory of this case, as the writ petit....

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....ppellant also called upon the respondent Income Tax Officer to furnish the reasons for reopening of the assessment, to enable the appellant to file their objections his objection. 9.By six separate intimations dated 26.04.2019, the respondent Income Tax Officer informed to the appellant the reasons for reopening the Assessment Years wherein it was stated that on perusal of Return of Income Tax filed by the appellant for the above Assessment Years during survey under Section 133 A of the Income Tax, 1961, it was noticed that the appellant had claimed expenses equivalent to 59.23%, 51.10%, 38.79%, 26.71%, 28.88% & 35.24% in the respective Assessment Years in question. 10.It was stated that on 18.03.2018, the appellant was called upon to....

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....f the Income Tax Act,1961. It is submitted that non furnishing of information will not ipso facto not amount to escapement of Income Tax. It is further submitted that the Authorities concerned could have made assessments under Section 143 (3) of the Act after due scrutiny. 15.Per contra the learned counsel for the revenue Mr.Narayanaswamy submits that the reassessment proceedings are well reasoned and require no interference and therefore prays for dismissal of all the six Writ Appeals. 16.We have considered the records. All the six notices issued under Section 148 of the income Tax Act, 1961 read identically with mutatis mutandis's changes in the date and the assessment years. The notice for the Assessment Year 2012 -13 reads as unde....