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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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Seeks to amend Notification No. 89/2020 dated 02 November 2020

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...., Sub-section (ii), vide number S.O. 3952(E), dated the 2nd November, 2020, namely:- In the said notification,- (I) for clauses (vii), (viii), (ix), (x), (xi) and (xii), the following clauses shall be substituted, namely:- "(vii) the earnings of the assessee shall be credited either to the account of the Government of Abu Dhabi or to any other account designated by that Government so that no portion of the earnings inures to any private person barring any payment made to creditors or depositors for loan or borrowing [as defined in sub-clause (a) of clause (ii) of Explanation 2 to clause (23FE) of section 10 of the Act] taken for the purposes other than for making investment in India; (viii) the assessee shall not have any loans or bor....

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....fication No…../……dated………published in the Official Gazette on……....... 2. In *my/our opinion and to the best of *my/our information and according to examination of books of account including other relevant documents and explanations given to *me/us, it is certified that the assessee *has/has not complied with the conditions as laid down under clause (23FE) of section 10 of theIncome-taxAct,1961 and those provided in the said notification specifying the assessee being the Sovereign Wealth Fund as specified person for the purposes of claiming exemption under the said clause(23FE). 2.1 *The conditions not complied with by the assessee are as under:- (a)…………&....

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....ng the previous year 5. Total amount of income eligible for exemption under clause (23FE) of section 10 of the Income-tax Act, 1961 (as per details in column 11 of table at item no. 6): 6. The opening balance (i.e. the closing balance as on the last date of the preceding financial year) of the investment made which is eligible for exemption under clause (23FE) of section 10 is ______________(in rupees) and details of the investment by the Sovereign Wealth Fund (SWF) during the period are as under: Sl. No. Date of inve-stment Amount of inves-tment Nature of investment (Instruc- tion 4) Nature of income (instruc- tion 5) Amount of income on investment during the year Details of the entity in which Investm....

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....(23FE) of section 10 of the Income-tax Act, 1961, that is, - a) Whether the government of foreign country wholly owns and controls the SWF, directly or indirectly Yes/No b) Mention the name of the government of foreign country which owns and controls the SWF, directly or indirectly c) Whether the government of foreign country owns and controls the SWF, directly or indirectly Directly/ Indirectly d) In case if government of foreign country owns and controls the SWF, indirectly give details of the chain of ownership e) Name of the law under which the SWF is set up and regulated f) Whether the earnings of the said fund are credited either to the account of the Government of that foreign country or to any other account designated ....

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....wer to (l) is yes, then provide the following details: (i) Name of the person from whom such loan or borrowing has been taken (ii) Amount of loan or borrowing at the beginning of the year (iii) Amount of loan or borrowing received during the year (iv) Amount of loan or borrowing repaid during the year (v) Amount of loan or borrowing at the end of the year n) Whether separate segmented account is maintained for income and investment in respect of investment which qualifies for exemption under clause (23FE) of section 10 of the Act Place:…………… Date:…………… (Signature and stamp/Seal of the signatory) Name of the signatory ……………&hel....