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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 failed to issue mandatory draft under section 144C(1); BVI company eligible under section 144C(15)(b), assessments invalidated

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Full Text of the Document

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....The ITAT affirmed that the assessee, a foreign company incorporated in the British Virgin Islands, qualified as an "eligible assessee" under section 144C(15)(b) and thus the AO was statutorily obliged to issue a draft assessment under section 144C(1). The AO proceeded to pass final assessment orders without issuing the mandated draft, rendering the final orders vitiated for non-compliance with the mandatory pre-draft procedure. The CIT(A)'s decision setting aside the impugned final assessments was upheld, and the Revenue's appeal was dismissed. The matter is remitted for fresh proceedings in accordance with the statutory scheme under section 144C.....