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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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Interest income from FDs with SCDCC Bank allowed as deduction under 80P(2)(a)(i). Revision under sec 263 not valid. Appeal allowed.

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Full Text of the Document

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....The Appellate Tribunal reviewed a case involving a revision u/s 263 related to deduction u/s 80P(2)(a)(i). The AO allowed interest income from FD investments as a deduction. The Tribunal noted a previous year's treatment by AO as "income from other sources" and rejection of the deduction claim. The CIT(A) later allowed the deduction for the previous year, stating the interest income was part of operational income u/s 80P(2)(a)(i). The Tribunal found the PCIT's revision u/s 263 invalid, as the interest income was deemed part of operational income due to statutory compulsions. The Assessment Order granting the deduction was upheld, and the PCIT's order u/s 263 was quashed. The appeal by the assessee was allowed.....