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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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Appeal fails; s.68 bogus loans, bogus purchases and notional interest additions deleted for lack of evidence, cross-examination

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Full Text of the Document

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....ITAT dismissed the Revenue's appeal and upheld CIT(A)'s deletion of all additions. The addition under s.68 towards alleged bogus unsecured loans was rejected as the assessee had furnished complete documentary evidence, lenders responded to s.133(6) notices, loans were repaid, creditors had sufficient financial capacity, and no defects were pointed out by AO; reliance on third-party statements without cross-examination was held untenable. The estimated addition on alleged bogus purchases at 0.5% was also deleted, CIT(A) having found, on facts, that AO's inference was erroneous and unsupported by evidence. Further, the addition of notional interest on supposed cash loans was deleted since the loans were through banking channels, duly recorded, with interest paid by bank, and penalty proceedings under ss.271D/271E had been dropped.....