How tax lawyers use Justis AI
Tax work is reading exact text under time pressure. A show cause notice arrives with thirty days to reply, the allegation rests on a return the client filed three years ago, and the answer turns on the section as it stood for that period, a circular issued since, and a ruling that settled the point in one High Court but not in another. Since 1 April 2026 there is also the question of which Act governs: the Income-tax Act 2025 for the current tax year, the 1961 Act for many notices still arising for earlier years.
Justis reads the notice with the client's papers. You upload the notice, the returns, the ledgers and the invoices to a project, and it sets each allegation against what the record shows, finds the provision and the authority that decide the point, and drafts the reply or the opinion in your format. Every figure carries the document and line it came from, and where the law is unsettled it says so instead of choosing a side for you.
01
Replying to a GST show cause notice
The problem
A show cause notice under section 73 or 74 of the CGST Act runs to twenty pages and a set of annexed spreadsheets. Each allegation has to be met from the record: the invoice, the return, the ledger entry and the provision it satisfies. For periods from 2024-25 onwards the notice will usually be under section 74A instead, with its own time limits.
The first questions are often the strongest. Is the notice within time for the section invoked? Does a section 74 notice actually allege fraud, wilful misstatement or suppression with particulars, or does it simply assert them to reach the longer period?
How Justis handles it
Justis reads the notice and its annexures, lists every allegation and the amount attached to it, and sets each one against the invoices, returns and ledgers in the project with the document and page or line. It checks the notice for jurisdiction and limitation under the section invoked, and whether the extended period is properly pleaded.
It then drafts the reply in Word, preliminary objections first, each ground cited to the provision, the notification or circular and the ruling that supports it, with the record references in the margin.
| What comes back | Example |
|---|---|
| Notice | Section 74 SCN dated 12.03.2026 for FY 2022-23, demand of ₹1.36 crore with interest and penalty |
| Allegations | 4: ITC on cancelled suppliers, ITC beyond s.16(4) time limit, short payment on rent, e-way bill mismatch |
| Record | Supplier registrations active on every invoice date; tax reflected in GSTR-2B (Ledger, lines 212 to 260) |
| Time limit | ITC for FY 2022-23 claimed in the October 2023 return, within the s.16(4) limit of 30 November 2023 |
| Extended period | No particulars of fraud or suppression; s.74 not available, demand if any lies under s.73 |
| Deliverable | Reply in Word with preliminary objections, grounds and record references |
Illustrative example. Names, figures and dates are invented; the provisions are real.
Read this show cause notice and its annexures against the returns, ledgers and invoices in this project. List every allegation with the amount, set out what the record shows for each with the page or line, check whether the notice is within time and whether the extended period is properly invoked, and draft the reply.
02
Reconciling input tax credit against GSTR-2B
The problem
Most ITC disputes come down to a reconciliation: the purchase register against GSTR-2B, supplier by supplier and invoice by invoice. It is two days of spreadsheet work before the legal argument can start, and the argument depends on getting it right.
The conditions in section 16(2) are cumulative, including the requirement that the invoice appear in the statement under section 16(2)(aa), so a mismatch on a single invoice can decide whether a credit is defensible.
How Justis handles it
Upload the purchase register, the GSTR-2B exports and the ledger. Justis matches them invoice by invoice and returns a grid: matched, missing from 2B, mismatched in value or tax, supplier cancelled, or claimed late, each with the line on both sides.
It totals the exposure by category, says which condition in section 16 each unmatched credit fails, and exports the grid to Excel as the annexure to the reply.
| What comes back | Example |
|---|---|
| Read | Purchase register of 4,812 lines, 12 months of GSTR-2B, ITC ledger |
| Matched | 4,655 invoices, ₹3.92 crore of credit |
| Not in 2B | 118 invoices, ₹21.4 lakh; 96 of them from 3 suppliers who filed late |
| Value mismatch | 31 invoices, ₹2.1 lakh, mostly rounding and debit notes |
| Supplier cancelled | 8 invoices, ₹1.7 lakh; cancellation effective after the invoice dates |
| Deliverable | Reconciliation grid in Excel with both-side references, and a summary note |
Illustrative example. Names, figures and dates are invented; the provisions are real.
Reconcile the purchase register against the GSTR-2B exports in this project for FY 2022-23, invoice by invoice. Give me a grid of matched, missing from 2B, value mismatch, supplier cancelled and claimed late, with the line on each side, total each category, and say which condition in section 16 each unmatched credit fails.
03
Reassessment notices and the question of which Act
The problem
The client receives a notice proposing to reopen an assessment for an earlier year. The Income-tax Act 2025 has been in force since 1 April 2026, but a reopening for an assessment year under the 1961 Act still runs through the 1961 procedure: the show cause under section 148A, the time limits in section 149 and the monetary threshold that decides whether the longer period is available.
The best answer is often jurisdictional. If the escaped income alleged is below ₹50 lakh and the three-year period has passed, the notice fails before the merits are reached.
How Justis handles it
Justis reads the notice, the information relied on, the return and the original assessment, identifies which Act and which procedure govern the year, and checks each jurisdictional condition: the period, the threshold, the approval and whether the information was already before the assessing officer.
It then drafts the reply to the show cause on jurisdiction and merits, with each proposition cited to the section and the ruling, and flags where a writ is worth considering if the objection is rejected.
| What comes back | Example |
|---|---|
| Notice | Show cause under s.148A(b), 1961 Act, dated 18.08.2026, for AY 2022-23 |
| Alleged | Unexplained credit of ₹38 lakh in a savings account |
| Governing law | 1961 Act procedure, as amended from 1 September 2024, for an assessment year before the 2025 Act |
| Time limit | AY ended 31.03.2023; the three-year period has passed and the amount is below the ₹50 lakh threshold for the longer period |
| Merits | Credit is a loan from a relative, with bank statement and confirmation on file (p. 14 to 19) |
| Deliverable | Reply to the show cause, jurisdiction first, in Word |
Illustrative example. Names, figures and dates are invented; the provisions are real.
Read this reassessment notice, the information relied on, the return and the original assessment. Tell me which Act and procedure govern this year, check every jurisdictional condition including the time limit and the ₹50 lakh threshold, then draft the reply on jurisdiction and merits.
04
Research and opinions on unsettled points
The problem
The client wants an opinion on a question the statute answers only in part. Is GST payable on a corporate guarantee given by a parent for a subsidiary's loan, and on what value? The answer depends on a rule inserted in October 2023, the circulars that followed, and whether the subsidiary can take full credit.
An opinion that states one view without the rule, the circular and the counter-argument is not one a client can rely on in an audit.
How Justis handles it
Justis searches the Acts, rules, notifications and circulars with Supreme Court, High Court and tribunal decisions, and builds the answer step by step: the provision, the amendment and its date, the circular and what it clarifies, and the decisions on each side. Every quotation links to its source.
It writes the opinion in your format, with a short answer, the analysis and the risk stated plainly, and marks where the position is unsettled rather than presenting it as settled.
| What comes back | Example |
|---|---|
| Question | GST on a parent's guarantee of a ₹50 crore loan to its subsidiary |
| Provision | Rule 28(2), CGST Rules, from 26 October 2023: 1% of the guaranteed amount a year, or the actual consideration if higher |
| Credit | Where the recipient is eligible for full input tax credit, the invoice value is deemed to be the open market value |
| Earlier periods | Before the rule, valuation contested; decisions summarised and linked |
| Short answer | Taxable; if the subsidiary takes full credit, declared value accepted and exposure is neutral |
| Deliverable | Opinion in Word with table of authorities |
Illustrative example. Names, figures and dates are invented; the provisions are real.
Research whether GST is payable on a corporate guarantee given by a parent company for its subsidiary's bank loan, and on what value, for periods before and after 26 October 2023. Cite the rule, the circulars and the decisions on each side, and write a short opinion with the risk stated plainly.
05
Tax review of a transaction's documents
The problem
In an acquisition, the tax questions sit across fifty documents: the share purchase agreement, the business transfer agreement, the intercompany agreements, the ESOP plan, the earn-out. Each can trigger withholding, capital gains, transfer pricing or GST, and the indemnity has to match the exposure.
The review usually happens in the last week of the deal, when there is no time to read everything twice.
How Justis handles it
Tabular review asks the same tax questions of every document in the data room: what is triggered, who bears it, what withholding applies, and whether the tax warranties and indemnity cover it. Each answer comes back as a cited cell, with the clause and page.
Justis then drafts the tax section of the diligence report, ranked by exposure, and proposes the tax indemnity and escrow language as tracked changes in the SPA.
| What comes back | Example |
|---|---|
| Documents | 54 in the data room, 2,310 pages |
| Withholding | Payment to a non-resident seller: withholding under the Income-tax Act 2025 not addressed in the SPA |
| Transfer pricing | Intercompany services at cost with no mark-up (Services agreement, cl. 5) |
| GST | Brand licence royalty paid to a foreign affiliate: reverse charge not reflected in returns |
| Indemnity | Tax indemnity capped at 10% of the price and limited to 3 years; flagged |
| Deliverable | Tax grid in Excel, diligence section and SPA mark-up in Word |
Illustrative example. Names, figures and dates are invented; the provisions are real.
Review every document in this data room for tax. For each, tell me what tax is triggered, who bears it, what withholding applies and whether the SPA warranties and indemnity cover it, citing the clause and page. Then draft the tax section of the diligence report and propose indemnity language as tracked changes.
06
Structuring memos
The problem
The client wants to sell a business division and asks whether to sell it as a going concern or sell the assets one by one. The answer runs through capital gains, the treatment of depreciable assets and stock, GST on the transfer and stamp duty on the documents, and each head can point a different way.
The memo has to show its working. The board will ask why, and the assessing officer may ask later.
How Justis handles it
Justis reads the balance sheet, the asset register and the term sheet, walks each option through income tax, GST and stamp duty, and computes the tax under each with the assumptions stated. It names the provision behind each step, including the GST exemption for the transfer of a going concern.
It writes the memo with a comparison table and a recommendation, and lists the conditions the transaction must meet for the recommended treatment to hold.
| What comes back | Example |
|---|---|
| Transaction | Sale of a manufacturing division for ₹42 crore |
| Slump sale | Capital gains on the division's net worth under the Income-tax Act 2025; single rate, no item-wise allocation |
| Itemised sale | Depreciable assets through the block, stock taxed as business income; higher total tax on these figures |
| GST | Transfer of a going concern exempt under Notification 12/2017-Central Tax (Rate); itemised sale taxable asset by asset |
| Conditions | Whole undertaking transferred, lump sum consideration, no values assigned to individual assets |
| Deliverable | Structuring memo with comparison table, in Word |
Illustrative example. Names, figures and dates are invented; the provisions are real.
Using the balance sheet, asset register and term sheet in this project, compare a slump sale of the division with an itemised sale of its assets across income tax, GST and stamp duty. Compute the tax under each with the assumptions stated, name the provision for each step, and recommend one with the conditions it depends on.
07
When the order arrives: appeal and pre-deposit
The problem
The adjudication order confirms the demand, and the client wants to know the same day whether to appeal, by when, and what must be paid first. A first appeal under section 107 of the CGST Act has to be filed within three months of communication, with a further month only for sufficient cause, and the pre-deposit must be made before it is admitted.
The grounds have to come from the order itself: the submission it did not deal with, the document it ignored and the provision it misread.
How Justis handles it
Justis reads the order against the reply and the record, lists each submission and whether the order dealt with it, and identifies the grounds, strongest first. It computes the last date and the pre-deposit, and notes where recovery of the balance is stayed once the deposit is made.
It drafts the grounds of appeal and the statement of facts in Word, each ground tied to a paragraph of the order and a page of the record.
| What comes back | Example |
|---|---|
| Order | Order under s.74 dated 12.08.2026, communicated 14.08.2026, tax of ₹96 lakh confirmed |
| Last date | Three months under s.107(1): 14 November 2026; further one month for sufficient cause to 14 December 2026 |
| Pre-deposit | 10% of the tax in dispute: ₹9.6 lakh, with the admitted amount paid in full |
| Not dealt with | 3 of 7 submissions, including the limitation objection (Reply, para 4) |
| Grounds | 6 grounds, each tied to a paragraph of the order and the record |
| Deliverable | Grounds of appeal and statement of facts in Word |
Illustrative example. Names, figures and dates are invented; the provisions are real.
Read this adjudication order against our reply and the record. List each submission and whether the order dealt with it, identify the grounds of appeal strongest first, compute the last date and the pre-deposit under section 107, and draft the grounds and the statement of facts.
Make it repeatable
Each client or dispute stays in its own project. Returns, ledgers, notices and orders are read as they arrive, so the reply to the next notice for the same period starts from everything already on file, not from what someone remembers.
When the same work comes back, save it once. A workflow carries your reply format and the steps your team runs on every notice; a skill carries a method, such as the way you test a notice for limitation or reconcile ITC. Attach either to a message with an @-mention, and use sub-agents to run the reconciliation and the research side by side.
- A limitation and jurisdiction check on every notice before the merits
- An ITC reconciliation grid in the same columns for every client
- A reply template with preliminary objections first, in your format
- A tax diligence grid for every data room
- Personal hearings, in English or Hindi, transcribed into the matter
