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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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Transfer Pricing Method for 15-Year Unsecured Loan Invalid; Section 80IAB Deduction Denied for Unclaimed Income Sources

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Full Text of the Document

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....ITAT upheld DRP's decision regarding jurisdiction on s.80IAB deduction, confirming DRP lacked authority where no variation was proposed in Draft Assessment Order. Assessee's claim for s.80IAB deduction on Income from Other Sources and Short-Term Capital Gains was rejected as it wasn't claimed in original return or Form 10CCB, violating s.80A(5) and s.80AC requirements. On Transfer Pricing, ITAT found both assessee's "other method" benchmarking and TPO's SBI overdraft comparison inappropriate for 15-year unsecured loan transaction. Matter remanded to TPO/AO for fresh benchmarking analysis with directions to provide hearing opportunity to assessee.....

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