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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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AO exceeded jurisdiction by adding income beyond section 148 reasons; reassessment order under section 147 quashed

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Full Text of the Document

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....The ITAT held that the AO exceeded jurisdiction by making additions in the reassessment order beyond the income specified in the reasons recorded under section 148. Although the reassessment was initiated for verification of unexplained investment in the purchase of immovable property, no adverse finding or addition was made on this issue. The AO proceeded to assess capital gains and disallow interest on home loans unrelated to the recorded reasons. The Tribunal reiterated that the AO cannot independently assess income outside the scope of the reasons recorded for reopening. Consequently, the reassessment order under section 147 was quashed, and the appeal of the assessee was allowed.....