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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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Appellate Tribunal Excludes Multiple Companies from Comparables in Transfer Pricing Case for Captive Service Provider.

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Full Text of the Document

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....The Appellate Tribunal held that negative working capital adjustment cannot be made for a captive service provider. L&T Infotech Ltd. and Infosys Ltd. were excluded from comparables as the assessee is a captive service provider compensated on a cost+mark-up basis. Persistent Systems Ltd. was excluded due to lack of segmental details. Infobeans Technologies Ltd. was found not functionally comparable. Tata Elxsi Ltd. was excluded as it generates revenue from product sales. Mindtree Ltd. & Nihilent Ltd. lacked segmental financials. Cygnet Infotech Pvt. Ltd. was excluded for not being a captive service provider. Cybage Software Pvt. Ltd. was excluded due to diversified activities. Batchmaster Software Pvt. Ltd. was remanded for further verifica.........

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