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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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Reassessment Notice Under Sections 148 and 148A Quashed as Time-Barred Applying Surviving Period Doctrine and TOLA

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....HC examined reassessment proceedings initiated under ss. 148 and 148A (new regime) in light of the SC ruling in Rajeev Bansal and the effect of TOLA and Ashish Agarwal. Applying the "surviving period" doctrine, HC held that, after excluding the periods mandated by SC for deemed stay and for assessee's reply, only one day remained for completion of s.148A(d) proceedings and issuance of a valid s.148 notice, which expired on 9.06.2022. The impugned notice dated 25.07.2022 was therefore held to be time-barred. HC rejected Revenue's contention that non-filing of reply extinguished limitation, and quashed the reassessment notice and consequent proceedings.....

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Reassessment Notice Under Sections 148 and 148A Quashed as Time-Barred Applying Surviving Period Doctrine and TOLA