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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ITAT directed fresh assessment u/s 263 for FMV of shares. Existing shareholders not taxable. Pr.CIT's revisional action unjustified.

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....The ITAT directed the AO to conduct a fresh assessment u/s 263 to determine the Fair Market Value (FMV) of shares issued u/s 56(2)(viib). Existing shareholders received substantial shares at a premium, with only a few new subscribers. Citing a precedent, it was found that taxing excessive premium on shares issued to existing shareholders is not applicable as no income accrues to them. The AO's actions were not erroneous or prejudicial to revenue. The Pr.CIT's revisional action lacked jurisdiction under Section 263, leading to the appeal being allowed, canceling the revisional order and restoring the AO's decision.....

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ITAT directed fresh assessment u/s 263 for FMV of shares. Existing shareholders not taxable. Pr.CIT's revisional action unjustified.