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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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Tax appeal partly allowed: commission allowed under s.37, gratuity disallowed u/s 40A(7), no notional interest u/s 36(1)(iii) (1)(iii)

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Full Text of the Document

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....ITAT partly allowed the assessee's appeal. It deleted the disallowance of sales commission paid to certain female agents, holding the AO and CIT(A) had proceeded on assumptions without examining their qualifications, association with the company, and long-standing involvement, and noting that in subsequent years 90% of such commission was allowed on identical facts. ITAT upheld disallowance of the gratuity provision, treating it as a mere provision for gratuity not paid into an approved gratuity fund and therefore not deductible. ITAT also deleted the interest disallowance on advances to a director, finding the assessee possessed sufficient interest-free funds, precluding any notional interest disallowance.....