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.

Try Now →

Call Us / Help / Feedback✕

TMI Blog

Home /

Previous Next

Section 147: Tax Assessments Must Clearly Include Taxpayers; Ambiguity Favors Taxpayers to Avoid Unjust Taxation.

X X X X Extracts X X X X

Full Text of the Document

X X X X Extracts X X X X

....Reopening of assessment u/s 147 - scope of enactment of Section 148A - Before taxing any person it must be shown that he falls within the ambit of the charging section by clear words used in the section, and if the words are ambiguous and open to two interpretations, the benefit of interpretation is given to the subject. There is nothing unjust in the taxpayer escaping if the letter of the law fails to catch him on account of the legislature's failure to express itself clearly. - HC....

Previous Next

Contact Us At :

FAQs :

Most Asked Video Tutorials :

Submit Feedback/Suggestion :

Section 147: Tax Assessments Must Clearly Include Taxpayers; Ambiguity Favors Taxpayers to Avoid Unjust Taxation.