Tax Appeal Grounds Drafter

---
name: tax-appeal-grounds-drafter
description: Drafts grounds of appeal against an already-passed tax assessment or order — each ground tied to a specific part of the order, factual and legal grounds kept distinct, and procedural grounds such as limitation or natural justice raised prominently. Use this whenever a user wants to appeal a tax order — including phrasings like "draft grounds of appeal against this assessment order", "we want to challenge this GST demand order", "prepare an appeal against this disallowance", "draft the grounds for the tribunal", or "challenge this order for lack of a hearing". India-specific. Distinct from tax-assessment-reply-drafter, which responds before an order is passed — this challenges one that already has been. Fires for any appeal against an income tax, GST, or other tax assessment or order, at any appellate forum.
---

# Tax Appeal Grounds Drafter

## What this does

Drafts the grounds of appeal against a tax assessment or order that has already been passed — the formal statement of why the order is wrong, ground by ground, for filing before the appellate authority. Each ground is tied to a specific part of the order being challenged, factual grounds are kept distinct from legal grounds, and any procedural defect capable of disposing of the whole order is raised prominently rather than buried among the merits grounds.

## Before you start

**The order being appealed.** The actual text — grounds cannot be drafted against an order that has not been read.

**The client's actual grievance with each part of the order**, from the client or instructing lawyer. This skill structures and argues the grievance; it does not invent one.

**The appellate forum and the specific appeal being filed.** Format, limitation period, and procedure differ by tax type and by level of appeal. Ask; do not assume.

Not blocking, ask once and proceed on what is confirmed: **limitation status.** If not confirmed, flag whether the appeal appears timely as a verification point rather than assuming it.

## Method

**1. Read the whole order once before drafting a single ground.** Understand the officer's or authority's complete reasoning first — grounds drafted issue by issue on a first pass routinely misstate what the order actually held, because a conclusion on one point is often built on reasoning stated under a different heading.

**2. List every distinct issue, addition, or disallowance in the order that the client wants to challenge, before drafting any single ground.**

**3. For each issue, state the ground precisely** — what the order held, and why it is wrong, tied to the specific part of the order rather than a generic assertion that could apply to any order of this type.

**4. Keep factual grounds and legal grounds distinct.** A ground that the officer got the facts wrong or ignored evidence submitted is argued differently from a ground that the wrong provision was applied or a binding precedent was disregarded — mixing the two muddies both.

**5. Do not cite a specific statutory provision, circular, or precedent as supporting a ground unless it is sourced this session or supplied by the user.** Where a ground would benefit from an authority that is not currently available, flag that rather than inventing one.

**6. Check for procedural grounds separately** — limitation, jurisdiction, natural justice or absence of a proper hearing, non-service of notice. These are threshold grounds capable of disposing of the whole order, and belong in their own place, raised prominently, not folded into the merits grounds.

**7. State the specific relief sought for each ground** — deletion of an addition, remand, or quashing — tied to what follows from that particular ground being accepted.

**8. Order the grounds logically**, procedural and jurisdictional grounds first, then substantive grounds in the sequence the issues appear in the order under appeal.

**9. Flag limitation as a verification point if not confirmed, and flag the appellate forum's specific filing format and requirements as needing verification** — these are forum-specific and change with procedural rules.

## Output

**1. Header.** Forum, the order being appealed (reference and date), appellant, date of the order, date of this appeal.

**2. Grounds of appeal.** Numbered, each tied to a specific part of the order, factual or legal basis stated, citing authority only where sourced or supplied.

**3. Relief sought.** Stated per ground.

**4. Procedural grounds, if any.** Stated distinctly and prominently, ahead of the merits grounds.

**5. Limitation.** Stated, flagged for verification if not confirmed.

**6. Points requiring verification.** Forum-specific filing and format requirements, and any authority needed for a ground but not currently sourced.

## Do not

Do not cite a statutory provision, circular, or judgment that is not sourced this session or supplied by the user.

Do not draft a generic ground that is not tied to the specific part of the order being challenged.

Do not assume the appeal is within limitation without flagging it as a verification point.

Do not conflate factual and legal grounds. Keep them distinct.

Do not omit a procedural ground the client wants raised, and do not bury it among the merits grounds.