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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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Section 40A(9) Expenses Allowed; Section 32AC Investment Allowance Denied for Power Generation Activities

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Full Text of the Document

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....The ITAT allowed the disallowance under section 40A(9) regarding payments to an educational society, holding such expenses as statutory obligations under the NCWA and not disallowable employee welfare expenses, following the jurisdictional High Court's precedent. The claim for investment allowance under section 32AC was denied, affirming that power generation activities do not qualify for this benefit. The disallowance under section 40(a)(ia) for TDS on interest deposited in court was deleted, as the assessee was not liable for TDS until actual payment to recipients. Expenses on abandoned coal mine development were held to be revenue in nature and allowable. Depreciation at 15% was upheld, recognizing mine-related infrastructure as plant and machinery.....