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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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Revision under Section 263 requires total lack of enquiry, not just inadequacy, for valid revision orders

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Full Text of the Document

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....The ITAT held that revision proceedings under Section 263 cannot be sustained where there is no total lack of enquiry by the AO, only inadequacy. The AO's investigation was confined to rental income, which was the principal issue, and thus not a complete absence of enquiry. An error or omission regarding the claim of interest under Section 24(a) amounts to inadequate enquiry, requiring the Pr. CIT to conduct independent inquiry before invoking revision powers. The Pr. CIT failed to demonstrate any inquiry or collect material to justify the revision of eight assessment orders, acting in a hurried and mechanical manner without proper application of mind. Consequently, the ITAT set aside the Pr. CIT's revision orders as legally untenable and allowed the assessee's appeal.....