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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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Tunnel Construction Company's Section 80IA Claim Rejected But Technical Service Fees Allowed As Business Expenditure

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Full Text of the Document

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....Taxpayer denied deduction under section 80IA as they failed to meet statutory requirements for infrastructure development projects. ITAT found that LMRCL, being a special purpose vehicle with 50:50 equity between Central and State governments, did not qualify as government authority/statutory body under section 80IA(4). Assessee's role was limited to tunnel construction per contract specifications. Regarding disallowance of technical service fees paid to Gulemark TPL JV, ITAT reversed AO's decision, holding that expenses were legitimate business expenditures deductible under section 37. Since AO had accepted these as revenue expenditure rather than capital expenditure, technical service fees were allowed as claimed. Revenue's appeals dismissed.....