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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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Penalty Proceedings Time-Barred: Initiation Date is Reference Receipt, Not Show Cause Notice Issuance.

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....Initiation of penalty proceedings u/s 271C and the limitation period for levying such penalty. The key points are: The penalty proceedings were initiated on the date of receipt of the reference for penalty proceedings (25.09.2014) and not on the date of issuance of the show cause notice (04.08.2014). The reference marked the first step for initiating penalty action, while the show cause notice provided an opportunity to the assessee to explain. The word 'initiated' means to begin, commence, or set in motion, as per dictionary meanings cited. The Supreme Court decision in Om Prakash Jaiswal v. D.K. Mittal was referred to for interpreting the expression 'initiate any proceedings'. Since the penalty order was passed beyond the limitation period from the date of initiation (25.09.2014), it was barred by limitation. The High Court upheld the Tribunal's decision in favor of the assessee.....