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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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2016 (3) TMI 1465

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....year 2008-09. Grounds of appeal in Revenue's appeal read as under: 1. That the ld. Commissioner of Income-tax (Appeal), Ranchi, erred in deleting the addition made by Assessing Officer totalling to Rs. 1,04,23,877/- under following heads:- Salary and Wages : Rs. 81,706/- Interest : Rs. 25,00,397/- Medical Expenses : Rs. 24,000/- Payment made to Contractor : Rs. 3,72,674/- Income from service render : Rs. 57,83,360/- Share of township maint. Cost : Rs. 2,87,904/- Leave encashment : Rs. 32,405/- Travelling expenses : Rs. 61,803/- Sales tax : Rs. 12,79,877/- 2. That the ld. Commissioner of Income-tax (Appeal), Ranchi, has erred by allowing claim ....

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....ad added total 1,08,80,408/- out of which an amount of Rs. 1,04,23,877/- was added pertained to prior period. It is noted that the assessee maintains books as per the mercantile system of accounting and it had different clients and offices spread throughout the country and hence, at the end of the financial year, it was not possible to account for all the expenditure incurred by the various offices and branch offices. It is also noted that there may be certain increase in rate and, hence, the difference was paid to the subsequent year. Vouchers have been received from the employees after 31st March of the financial year for the expenses incurred in the previous year. It is also noted that looking into the turnover of several hundred crores ....

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....case. It has also been submitted that necessary details were duly submitted before the Assessing Officer. It has also been submitted that the relevant vouchers of the expenditures contained the supporting evidence. It is not the case of the Assessing Officer that any short-coming has been noted in the vouchers maintained by the assessee. In these facts and circumstances, it is assessee's claim that the Assessing Officer has erred in making the disallowance and ld. CIT(A) is quite correct in deleting the disallowance. 4. Upon careful consideration and hearing both the parties, we are of the considered opinion that the assessee's submissions are cogent. The assessee is a public sector undertaking and it has got a vast organization. In its ....