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Income tax, transfer pricing, Goods and Services Tax, customs and excise. Show-cause replies, ITAT appeals, High Court writs and Supreme Court SLPs. Anti-Profiteering Authority and Advance Ruling proceedings.
Indian tax practice operates across two parallel statutory systems — direct tax under the Income Tax Act, 1961 and indirect tax under the Central Goods and Services Tax Act, 2017 — overlaid with the Customs Act, 1962 and the legacy excise framework. The firm advises and represents enterprises, individuals and foreign-invested entities across both systems.
Tax disputes increasingly turn on procedural questions — limitation, jurisdiction, opportunity of hearing — as much as on substantive law. The firm's tax practice is built around procedural mastery and substantive depth in equal measure.
Tax matters are won at the assessment, lost at the show-cause, and remembered at the appeal. The earlier the engagement, the better the outcome.
Assessment, reassessment under Section 147/148, appeals before the CIT(A), DRP and ITAT.
Show-cause replies, GSTAT, ITC denial, refund disputes and writ challenges.
TP audits, DRP proceedings, APA negotiations and MAP applications.
Classification, valuation, duty disputes, SVB references and CESTAT appeals.
The income tax practice covers assessment, reassessment, search-related proceedings and appeals. Reassessment under Section 147/148 — substantially restructured by the Finance Act 2021 and refined by Union of India v. Ashish Agarwal — remains the single most active area of direct-tax litigation. The firm represents taxpayers in show-cause notices under Sections 143(2), 142(1) and 148, reassessment proceedings under the post-1 April 2021 regime, search-related assessments under Sections 153A and 153C, appeals before the Commissioner (Appeals), Dispute Resolution Panel proceedings under Section 144C, ITAT appeals, tax appeals to the High Court under Section 260A and the Supreme Court under Section 261.
The Goods and Services Tax has reshaped indirect-tax disputes. The principal contested areas are input-tax-credit denial, refund claims, classification disputes, anti-profiteering proceedings and the constitutional validity of specific notifications. The firm acts in show-cause notice replies under Section 73 (without fraud) and Section 74 (with fraud), refund applications under Section 54, ITC disputes under Section 17, writ petitions challenging blocked credits and notice issuance, appeals before the GSTAT and High Courts, and Advance Ruling Authority proceedings.
Transfer-pricing disputes turn on functional analysis, comparable-company selection, and the application of the Most Appropriate Method under Section 92C and Rule 10B. The firm advises on TP audits, DRP proceedings and ITAT appeals, and acts in mutual-agreement-procedure (MAP) negotiations under the relevant Double Taxation Avoidance Agreement.
The customs practice covers classification disputes, valuation under Section 14 and the Customs Valuation Rules 2007, special-valuation-branch references for related-party imports, and duty-drawback claims. Legacy excise matters continue to surface in pre-GST disputes, particularly in CESTAT appeals on classification and CENVAT credit.
Tax appellate practice has its own discipline. Grounds of appeal must be precisely framed. Statements of fact must distinguish between admitted and disputed elements. The principles laid down in CIT v. Vatika Township and CIT v. Calcutta Knitwears apply to interpretive questions; the Engineering Analysis line and Vodafone International Holdings have shaped cross-border taxation disputes.
The tax bench reads what is filed. The firm files what the bench will read.