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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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2022 (10) TMI 792

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....s ITO, Ward 12(1), New Delhi, ITO, Ward 49(1), Delhi., DCIT, Circle 10(1), New Delhi, ACIT, Circl e23(2), New Delhi., ITO, Ward 62(1), Delhi., ACIT, Circle 61(1), New Delhi, Assistant Director of Income Tax, CPC Bangalore, DCIT, CC-31, Delhi Jhandewala Ext., ITO, Ward-14(3), Delhi, Deputy Commission of Income Tax, CPC, Circle-34(1), Delhi., ITO, Ward 50(4), Delhi., ITO, Ward 12(3), Delhi For the Assessee : Shri Lalit Mohan, CA, Shri D.K. Gupta, CA, Shri Hawa Singh, CA Shri Mukul Gupta, CA, Shri Baldev Raj, CA, Shri Aman Garg, CA, Shri Rupender Shah, CA, Shri Tanpreet Kohli, CA. For the Revenue : Ms. Kajal Singh, Sr.D.R. ORDER PER BENCH : The present appeals are filed by the above mentioned assessees feeling aggrieved by ....

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....23 prospectively. The Learned Commissioner of Income-Tax (Appeals) passed the order without going through the facts and explanations filed by the Appellant. The Learned Commissioner of Income-Tax (Appeals) is without properly appreciating the fact and that he further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time." 3. Similar grounds with different amounts and assessment years have been raised in other appeals but however, the sum & substance and the issues involved in all the appeals are identical. 4. Before us, at the outset, Learned AR submitted that the sole grievance of the assessee is confirming the additions on account of delay in deposit of empl....

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....rom any of his employees to which the provisions of sub clause (x) of Clause (24) of Section 2 applies. 7. We have heard the rival submissions and perused the material available on record. The issue is no more res-integra. The issue has already been settled in favour of the assessee by various judicial pronouncements by the Tribunal. The Hon'ble Jurisdictional High Court of Delhi in the case of PCIT vs Pro Interactive Service (India) Pvt.Ltd. in ITA No.983/2018 [Del.] order dated 10.09.2018 held as under:- "In view of the judgement of the Division Bench of Delhi High Court in Commissioner of Income Tax versus AIMIL Limited, (2010) 321 ITR 508 (Del.) the issue is covered against the Revenue and, therefore, no substantial question....