Practice area
Taxation
Direct tax, GST and transaction tax advice, with representation from assessment through appeal.
The Tax Environment
Indian tax practice has two distinct rhythms. Direct tax is undergoing the transition to the Income-tax Act, 2025, alongside a faceless assessment and appeal process that has changed how a case is built — the written submission and the documentary record now carry weight that oral hearing once did. Indirect tax is dominated by GST, where the volume of departmental notices, input tax credit disputes and classification questions continues to grow.
For cross-border structures, treaty interpretation, permanent establishment exposure, the General Anti-Avoidance Rule, place of effective management, transfer pricing and withholding on payments to non-residents all bear on the same transaction, often pulling in different directions.
Tax rarely arrives as a discrete question. It surfaces inside an acquisition, a financing, a restructuring or a property transfer — which is why we prefer to be in the room at the structuring stage rather than the assessment stage.
How We Support You
We advise on the tax consequences of transactions and structures — acquisitions, reorganisations, financings, property transfers, and inbound and outbound investment — and on the day-to-day questions that carry real exposure: withholding on cross-border payments, GST classification and place of supply, input tax credit eligibility, and permanent establishment risk.
On the contentious side we handle the full progression: responding to notices, assessment and reassessment representation, first appeals, appeals before the Income Tax Appellate Tribunal and the GST Appellate Tribunal, writ petitions where jurisdiction or natural justice is at issue, and appeals to the High Courts. We work alongside chartered accountants where compliance and certification sit with them.
Who We Act For
Indian companies and groups, multinational subsidiaries, promoters and high net worth individuals, funds and investment vehicles, real estate and infrastructure businesses, and non-residents with Indian income or a treaty question.
What We Handle
The work inside this practice. Each has its own page setting out what it covers, how it is sequenced and where it is heard.
Transaction and Structuring Tax
Tax analysis of acquisitions, slump sales and business transfers, amalgamations and demergers and the conditions for tax neutrality, capital gains computation and indirect transfer rules, characterisation of consideration, and stamp duty and GST interaction on transaction documents.
Read moreInternational Tax and Treaties
Double taxation avoidance agreement interpretation and beneficial ownership, permanent establishment and business connection analysis, place of effective management, withholding on payments to non-residents and Section 195 certificates, royalty and fees for technical services characterisation, equalisation levy, and GAAR risk assessment.
Read moreGoods and Services Tax
Classification and rate determination, place and time of supply, input tax credit eligibility and reversal, valuation and related party supplies, reverse charge, refunds including export and inverted duty structures, e-invoicing and e-way bill compliance, and anti-profiteering.
Read moreTransfer Pricing
Related party transaction policy and benchmarking support, documentation and master file and country-by-country reporting obligations, advance pricing agreements, safe harbour evaluation, and defence of transfer pricing adjustments in assessment and appeal.
Read moreTax Assessment and Dispute Resolution
Response to notices under Sections 142, 143 and 148, faceless assessment representation, Dispute Resolution Panel proceedings, GST show cause notices and adjudication, and appeals through the departmental and tribunal hierarchy.
Read moreTax Litigation
Appeals before the Commissioner (Appeals) and the Income Tax Appellate Tribunal, the GST Appellate Tribunal, writ petitions before the High Courts on jurisdiction, limitation and natural justice, and appeals to the High Courts and the Supreme Court on substantial questions of law.
Read morePersonal and Succession Tax
Residential status and taxation of foreign income, taxation of trusts and family arrangements, gift and inheritance consequences of succession planning, capital gains on property and securities, and disclosure obligations for foreign assets.
Read more
How the Work Is Sequenced
Indicative stages and what each produces. Timelines depend on the case. Where we can give a realistic range, the FAQs below say so.
Position and exposure review
The transaction or issue analysed against statute, treaty and current case law, with the exposure quantified and the strength of the position stated plainly — including where it is weak.
Structuring or remediation
Where the case is forward-looking, structuring options with the tax cost of each. Where an exposure already exists, the options for regularising it and their consequences.
Documentation and record
Contemporaneous documentation built to support the position — agreements, board records, benchmarking and valuation. Faceless assessment rewards a good written record and punishes a thin one.
Notice and assessment
Replies and submissions with supporting evidence, and management of the assessment timetable. Most cases are won or lost at this stage rather than on appeal.
Appeal
Appellate strategy including stay of demand, grounds of appeal, and a view on whether to litigate or settle taken on the numbers rather than on principle.
Jurisdictions, Forums and Regulators
Where cases in this practice are heard, filed or determined.
- Income Tax Appellate Tribunal, Hyderabad and Bengaluru benches
- Commissioner of Income Tax (Appeals); Dispute Resolution Panel
- GST Appellate Tribunal; adjudicating and appellate authorities under the CGST and SGST Acts
- Authority for Advance Rulings and the GST Advance Ruling Authorities
- High Court of Telangana; High Court of Andhra Pradesh; High Court of Karnataka
- Supreme Court of India
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Frequently Asked Questions
General information about how this practice works. It is not legal advice and does not create a lawyer–client relationship.
Do you handle tax compliance and return filing?
No. We advise on positions, structures and disputes, and appear in assessment and appellate proceedings. Return filing, audit and certification sit with chartered accountants, and we work alongside yours — or can suggest firms we deal with regularly.
We have received a reassessment notice. What are the first steps?
Check the limitation period and whether the procedural preconditions were satisfied, because a jurisdictional defect is often the strongest available answer. Then assess the substantive position and preserve the documentary record. Respond within time — a delayed reply narrows your options considerably.
How long do tax appeals take?
First appeals commonly take one to three years, and appeals before the Income Tax Appellate Tribunal a further two to four, though the position varies by bench and by the age of the case. This is why we advise on stay of demand at the outset and give a settle-or-litigate view based on the amount at stake rather than on the merits alone.
Can input tax credit be denied because our supplier did not pay GST?
Credit eligibility depends on the statutory conditions, including that tax has actually been paid to the government, and departments do raise mismatch demands on this basis. There is a substantial body of case law on the position of a bona fide recipient. Practically, supplier verification and contractual protection are worth more than the eventual argument.
Is our foreign parent's service fee subject to withholding?
It depends on characterisation — fees for technical services, royalty, or business profits — on the treaty, on whether there is a permanent establishment or business connection, and on whether the make available test is met where the treaty contains one. It is worth resolving before the invoice is raised rather than after the payment.
Does GAAR affect ordinary commercial structuring?
GAAR targets arrangements whose main purpose is a tax benefit and which lack commercial substance, above a monetary threshold. Genuine commercial structuring with documented business rationale is not its target, but the documentation of that rationale is what carries the point. We advise on structuring and on the contemporaneous record together.