Advisory on a specific transaction
A written position on the tax consequences of a defined transaction, setting out the facts relied on, the provisions applied, the conclusion, and the strength of the position with its principal risks identified.
OUR EXPERTISE
Tax Advisory
Direct tax, indirect tax and representation — advised from the charging provision outward.
Discuss your requirementsOUR APPROACH
Clear thinking.
Considered advice.
Tax positions fail for a predictable reason: the answer was located before the question was framed. A rate was applied, a notification was cited, a precedent was quoted — without first establishing what the transaction was, when the liability arose, and on whom the law fastens it.
We read the charging and machinery provisions before the circulars. Departmental guidance is important and we track it closely, but it interprets the statute rather than replacing it, and the distinction decides cases.
We document the reasoning contemporaneously, while the facts are fresh. A position taken today may be examined five years from now by an officer who has only the file. What is in the file, at the time, determines the outcome.
We tell you the strength of a position honestly — settled, arguable, or aggressive — and what each one implies for disclosure, provisioning and the likelihood of litigation. Certainty that does not exist is not something we will manufacture.
PRACTICE AREAS
Three connected disciplines.
Direct Tax
Corporate and international tax advice under the Income-tax Act, 1961 and India’s treaty network, covering the position taken, the compliance that follows from it, and the evidence that supports it.
- Corporate tax advisory, effective tax rate planning and regime selection
- Withholding tax analysis on domestic and cross-border payments, including Section 195 certification
- Tax treaty interpretation, permanent establishment analysis, residency and beneficial ownership
- Transfer pricing: method selection, benchmarking studies, local file, master file and CbCR
- Business reorganisation tax: mergers, demergers, slump sales and capital reduction
- Capital gains planning, including for unlisted shares, immovable property and business transfers
- Return preparation and review, tax audit under Section 44AB, and provisioning support
- Expatriate and cross-border individual taxation, including short-stay and social security positions
Indirect Tax and GST
Goods and Services Tax and residual indirect tax advice, focused on the questions that actually generate disputes: classification, place of supply, valuation and credit eligibility.
- Classification and rate determination, and advance ruling support where the position is genuinely unsettled
- Place and time of supply analysis for goods, services, and mixed and composite supplies
- Input tax credit eligibility, apportionment, blocked credits and reversal computation
- Export, SEZ and deemed export treatment; zero-rating; refund claims and follow-through
- Cross-charge and input service distributor positions for multi-state and multi-registration groups
- Reverse charge, e-invoicing and e-way bill compliance design
- GST health checks, annual return and reconciliation support (GSTR-9 and 9C)
- Customs classification, valuation and duty exemption advice, and FTP scheme benefits
Litigation and Representation
Representation before tax and appellate authorities, built on the premise that a case is won or lost in how the record is assembled — long before the hearing.
- Notice review and response strategy, including reassessment and faceless assessment proceedings
- Assessment and audit representation before income tax and GST authorities
- Appeals before the Commissioner (Appeals), the Income Tax Appellate Tribunal and GST appellate authorities
- Briefing and support to counsel for High Court and Supreme Court matters
- Advance rulings, mutual agreement procedure and advance pricing agreements
- Rectification, stay of demand, penalty and prosecution defence, and settlement evaluation
- Litigation portfolio review: assessment of exposure, provisioning and cases worth closing rather than fighting
WHAT WE DO
The substance
of the work.
Direct tax, indirect tax and representation — advised from the charging provision outward.
Ongoing tax compliance and support
Return preparation and review, withholding compliance, GST filings and reconciliations, and a maintained compliance calendar with accountability for each item.
Health checks and exposure reviews
Review of past positions to identify exposure before the department does, quantify it, and determine whether voluntary correction is available and advisable.
Representation and dispute management
End-to-end conduct of assessment, appellate and refund proceedings, including submissions, evidence assembly, hearings and coordination with counsel.
WHO WE HELP
Is this the right
support for you?
- Companies with cross-border transactions, related-party dealings or treaty positions to defend
- Multi-state businesses managing GST classification, credit and place-of-supply complexity
- Groups carrying open assessments, notices or appellate matters
- Businesses undertaking a reorganisation, acquisition or asset transfer
QUESTIONS WE ARE ASKED
Start with the decision
in front of you.
- Is the position we have been taking for years actually defensible?
- What withholding applies to this cross-border payment, and can a treaty rate be claimed?
- Are we entitled to the input tax credit we have been claiming?
- This matter has been in appeal for four years — is it worth continuing?
CONNECTED EXPERTISE
Explore related practices.
LET’S START WITH YOUR QUESTION
Bring clarity to
your next decision.
Describe the tax advisory matter you are facing. A partner from the relevant member firm will respond directly.