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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Section 147: No Extension for Reopening Income Tax Assessment; Only Unassessed Income Can Be Re-evaluated.

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....Reopening of assessment u/s 147 - third proviso - computation of period of limitation - the said proviso does not in any manner extend the period within which action under Section 147 of the Act can be initiated by the Department. It merely empowers the AO to assess or reassess such income, which is not involved or is the subject matter of any appeal, reference or revision, and has escaped assessment. It does not grant any further extension of time to the Department to initiate a proceeding u/s 147 of the Act. - HC....

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Section 147: No Extension for Reopening Income Tax Assessment; Only Unassessed Income Can Be Re-evaluated.