Direct Tax

A tax audit is mandatory when business turnover exceeds ₹1 crore in a financial year, or when professional receipts exceed ₹25 lakh — higher thresholds apply when at least 95% of receipts and payments are digital.

• Records review and sampling — trial balance, tax-sensitive ledgers, loan confirmations, statutory payments.
• Form 3CD disclosure preparation — depreciation, Section 43B payments, ICDS compliance, related-party transactions.
• Coordination with statutory auditors where engagements overlap.
• Typical turnaround: 3–6 weeks from records handover to filing, depending on entity size and the state of the books.

We run the recurring direct-tax calendar — returns, TDS/TCS, and advance tax — so nothing slips through deadlines.

We represent clients through the full direct-tax dispute cycle — from scrutiny assessment under Section 143(3) to appeals before CIT(A) and the Income-tax Appellate Tribunal.

• Scrutiny assessments — Section 143(3): drafting submissions, attending e-hearings, filing paper books.
• Rectifications — Section 154: correction of apparent errors in intimations, assessment, appellate or revision orders.
• Appeals at CIT(A) — Section 246A: first-level appeals against AO orders; grounds drafted to anticipate ITAT-level arguments.
• Appeals at ITAT — Section 253: second-level appeals, paper-book preparation, oral arguments.
• Revisions — Sections 263 and 264: CIT-initiated corrections of erroneous orders, or assessee-initiated revisions as an alternative to appeal.
• Search, survey and summons: responses to Section 131/133A notices, protecting client rights through the process.
• Advance Rulings (residents): application and representation before the Authority for Advance Ruling.
• Compounding applications: filings before the CCIT where prosecution has been initiated.

Specified domestic transactions between related parties must be reported in Form 3CEB under Section 92E when they exceed ₹20 crore in aggregate during the financial year.

• Form 3CEB preparation and certification by a chartered accountant before the return due date.
• Transfer pricing documentation — functional, asset and risk analysis per Rule 10D.
• Benchmarking against comparable uncontrolled transactions where available; method justification where not.
• Defence of methodology during TPO-led assessments if raised.

Before a transaction, buyers and lenders need a clean read on tax exposure — pending assessments, withholding history, and unreported liabilities.

• Historical returns (income tax and TDS/TCS) reviewed for gaps, aggressive positions, and audit risk.
• Open assessments, appeals and recovery proceedings status with authorities.
• Contingent liabilities quantified and presented against the deal timeline, with representations and warranties drafted accordingly.

Structuring decisions and one-off transactions carry direct-tax consequences that are easier to price in upfront than to unwind later.

• Transaction structuring — partnerships, buy-sell arrangements, family settlements, M&A, ESOP design.
• Written opinions on provisions where the statute alone is ambiguous — treaty override, GAAR exposure, capital-vs-revenue classification.

Sections 92 to 92F require international transactions between associated enterprises to be priced at arm's length, using one of five prescribed methods.

• Comparable Uncontrolled Price (CUP) — when comparable third-party prices exist.
• Resale Price Method (RPM) — for distribution arrangements with limited value-add.
• Cost Plus Method (CPLM) — for contract manufacturing and routine services.
• Profit Split Method (PSM) — for integrated operations and unique intangibles.
• Transactional Net Margin Method (TNMM) — the most commonly applied method in India in practice.

Cross-border taxation adds Master File, Country-by-Country Reports, and Form 15CA/15CB certifications on top of the core compliance calendar.

• Form 3CEB — transfer pricing certification, as above.
• Master File (Rule 10DA) and Country-by-Country Report (Rule 10DB) — under BEPS Action 13, for multinational groups above the prescribed threshold.
• Form 15CA / 15CB — self-declaration + CA certificate for remittances to non-residents. Banks won't process the outbound transfer without it where it applies (see Rule 37BB for exceptions).
• Flipside/equalisation-levy returns — where applicable to e-commerce or digital advertising supplies.

We represent clients in transfer-pricing assessments under Section 92CA, at the Dispute Resolution Panel, and before the Authority for Advance Ruling on cross-border positions.

• TP assessments — Section 92CA: submissions before the Transfer Pricing Officer; follow-through at the DRP, CIT(A) or ITAT.
• Dispute Resolution Panel (DRP): objections to draft assessment orders, particularly on TP adjustments and PE attribution.
• Advance Rulings — Section 245O: on non-resident transactions, tax liability of non-residents, resident transactions with non-residents, and GAAR applicability.

Inbound and outbound investments need tax structuring that matches the commercial intent — entity form, jurisdiction, ownership and exit.

Double Taxation Avoidance Agreements often provide relief over domestic law, but the interaction between the two is where disputes arise.

• Opinions on DTAA vs. domestic-law interaction — Permanent Establishment, royalty and FTS, capital-gains article, business-profits article.
• Residency determinations and tie-breaker analysis, including POEM for companies.
• Withholding tax rate determination on specific payments, documented for bank and audit use.