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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 paid on funds invested in partnership firm allowed as deduction.

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Full Text of the Document

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....The ITAT allowed the assessee's appeal and held that the disallowance of interest expenditure claimed as a deduction against interest income from the partnership firm was not sustainable. The assessee had sourced funds from both interest-bearing loans and non-interest-bearing funds, which were majorly invested in the capital of partnership firms for business purposes. The revenue contended that since the investment did not earn any income except from one firm, the interest paid u/s 36(1)(iii) was not allowable. However, the ITAT observed that the commercial expediency must be considered for allowability u/s 36(1)(iii), and the revenue did not raise any contention in this regard. The ITAT noted that without establishing a one-to-one match, i.........