Every business decision carries tax implications that can significantly impact profitability and long-term growth. With tax and regulatory frameworks—both in India and globally—undergoing rapid transformation, navigating this evolving landscape requires expert insight at every stage, from planning through compliance.

We focus on quality, reliability, and real-time responsiveness to meet the diverse and dynamic needs of our clients. Our approach ensures high partner and management involvement, enabling swift decision-making and delivering value through a deep understanding of client objectives.

With shorter communication chains, more senior-level engagement, and empowered client service teams, we offer agile, strategic, and integrated solutions that match the pace of modern businesses.

Our Tax and Regulatory Services Include:

• Direct Tax Services : Advisory, planning, and compliance support in line with domestic tax regulations

• Indirect Tax Services: GST advisory, compliance, audits, and representation

• Transfer Pricing: Planning, documentation, and dispute resolution, aligned with global standards

• Financial Services: Specialized tax and regulatory advice for financial institutions and intermediaries

• Transaction Tax: Structuring, due diligence, and tax planning support for mergers, acquisitions, and restructuring

• Expatriate Taxation: End-to-end solutions for global mobility, including tax planning, compliance, and payroll support for expatriates

Direct Tax

In today’s complex tax environment, businesses require more than just compliance—they need insight, strategy, and foresight. Our team of seasoned tax professionals provides a comprehensive suite of direct tax advisory, litigation, regulatory, and compliance services to help clients make informed decisions and manage risk efficiently.

Integrated Tax and Regulatory Expertise

We offer a broad range of fully integrated tax and regulatory services, combining technical expertise with commercial understanding. As India becomes an increasingly attractive investment destination, our specialists support businesses at every stage of their lifecycle—helping them seize opportunities, remain compliant, and minimize risk.

We also assist clients in managing cross-border tax matters by providing structured advice on complex international transactions, helping them optimize returns while staying ahead of global tax developments.

Who We Serve

Our tax solutions are tailored for:

• Large multinational corporations

• Mid-sized enterprises

• High-net-worth individuals

• Entrepreneurs seeking strategic growth

Our goal is to minimize both business and personal tax exposure through legitimate planning and ongoing awareness of evolving tax regulations in India and abroad.

Service Categories

1.Corporate Tax Services

We help clients navigate increasingly complex tax legislation through proactive planning and compliance strategies.

Key Offerings:

• Corporate tax advisory and planning

• Statutory compliance support

• Tax diagnostic reviews and risk mitigation

• Tax withholding health checks

• Tax minimization strategies and deduction planning

• Capital structure and debt-equity ratio optimization

• Tax implications on EPC/turnkey contracts

• Review of ICDS, Ind-AS, POEM, GAAR applicability

• FIN-48 compliance support

2. Tax Compliance

End-to-end assistance in meeting tax compliance requirements.

Our services include:

• Withholding tax returns preparation and filing

• Advance tax planning and optimization

• Corporate tax return preparation and filing

• Tax return filing for overseas entities operating in India

3. International Tax Services

Our aim is to help businesses optimize their global tax footprint while ensuring full compliance across jurisdictions.

Key Areas of Expertise:

• Outbound investment advisory and due diligence

• Treaty analysis and international tax planning

• BEPS & Multilateral Instrument (MLI) advisory

• Equalisation levy and digital payments taxation

• Non-resident taxation (e.g., shipping companies)

• Investment treaty interpretation

• Mutual Agreement Procedure (MAP) assistance

• Advance Ruling application support

4. Tax Representation & Litigation Services

We offer strategic representation and litigation support to handle audits, assessments, and disputes at all stages.

Our Litigation Services Include:

• Representation before tax authorities during audits and investigations

• Litigation before CIT(A), DRP, ITAT

• Support to legal counsel for High Court/Supreme Court representation

• Advisory on litigation strategy and execution

• Litigation history reviews and risk analysis

• Evaluation of uncertain tax positions and remediation support

In the dynamic landscape of indirect taxation, particularly under the Goods and Services Tax (GST) and Customs law, businesses must remain proactive, compliant, and strategically aligned. Our experienced team provides end-to-end support across advisory, compliance, litigation, and strategic review to help you manage your tax exposure and meet evolving regulatory demands.

Advisory Services

We help clients assess and plan for the tax impact of their business operations and transactions. Our advisory offerings include:

• Evaluation of tax implications on existing and proposed business transactions

• Contract and agreement review to identify GST impact across procurement, manufacturing, and distribution

• Assistance in determining optimal valuation models for related-party transactions under GST, aligned with transfer pricing principles

• Review and validation of legal positions adopted under GST, with suggestions for optimization

• Guidance on compliance with anti-profiteering rules under GST

• Advisory on import/export of goods under the Customs Act, 1962

• Assistance with Customs valuation in related-party import transactions

• Advice on duty-free incentive schemes under the Foreign Trade Policy

Compliance Services

Staying compliant with GST and related legislation is crucial for risk mitigation and operational continuity. Our compliance services include:

• Assistance in obtaining GST and other statutory registrations

• Verification of input tax credit (ITC) and identification of ineligible credits

• Review of periodic tax liability computations

• Preparation and filing of GST returns and other periodic filings

• Implementation of GSP/ASP solutions for seamless compliance management

• Filing of statutory applications before relevant authorities

Litigation Support

We offer strategic and responsive support in handling indirect tax disputes, inquiries, and clarifications:

• Drafting responses to notices, inquiries, and communications from tax authorities

• Assistance with filing appeals against appellate orders

• Representation before GST and Customs authorities, including coordination with external counsel where needed

• Filing of advance ruling applications for clarity on ambiguous issues

Other Services

We support your tax function with strategic reviews, training, and audit preparedness:

• Due diligence reviews from an indirect tax perspective (for M&A, investment, or internal controls)

• Health-check reviews to assess the adequacy of compliance systems

• Representation and technical assistance during departmental audits

• Support in preparing and filing representations before Advance Ruling or other tax authorities

• Training for management and staff on key GST provisions and updates

Indirect Tax

In India, international taxation refers to the rules and regulations governing cross-border transactions, including income earned by foreign entities in India and by Indian residents from abroad. Here are the main types of international taxation applicable in India:

🔹 1. Based on Taxation Principles

A. Residence-Based Taxation

• Indian residents are taxed on their global income.

• Applies to:

  • Individuals who qualify as Residents and Ordinarily Residents (ROR).

  • Indian companies and firms.

B. Source-Based Taxation

• Non-residents and foreign companies are taxed on income sourced in India.

• Common examples:

  • Income from business operations in India.

  • Royalties or fees for technical services received from Indian entities.

  • Capital gains from assets located in India.

🔹 2. Taxation of Different Categories of Income

A. Business Income

• Taxed in India if the non-resident has a business connection or a permanent establishment (PE) in India.

• Governed by Section 9 of the Income Tax Act and applicable tax treaties.

B. Royalty and Fees for Technical Services (FTS)

• Taxable if:

  • Paid by an Indian resident, or

  • The services are used in India.

• Subject to withholding tax (usually 10–15%, depending on the treaty).

C. Capital Gains

• Gains from transfer of shares, property, or assets located in India are taxable in India, even for non-residents.

• Tax rate depends on whether gains are short-term or long-term.

D. Interest Income

• Taxed if paid by a resident or relates to a debt used in India.

• Subject to withholding tax (e.g., 5% under Section 194LC for ECBs).

🔹 3. Key Mechanisms & Provisions in Indian International Taxation

A. Withholding Tax (TDS for Non-Residents)

• Indian payers must deduct tax at source when paying to non-residents for:

  • Royalty

  • Interest

  • Technical services

  • Dividends (in some cases)

B. Double Taxation Avoidance Agreements (DTAAs)

• India has DTAAs with over 90 countries.

• These treaties:

  • Avoid double taxation,

  • Provide lower tax rates (like 5%, 10%),

  • Define permanent establishment (PE) rules.

C. Transfer Pricing Regulations

• Apply to international transactions between associated enterprises.

• Requires pricing to be at arm’s length.

• Mandatory documentation and reporting under Income Tax Act.

D. Equalisation Levy / Digital Tax

• Tax on digital services provided by foreign companies to Indian users.

• Currently:

  • 6% on online advertising revenue (Section 165),

  • 2% on e-commerce supplies/services by non-residents (Section 165A).

E. General Anti-Avoidance Rules (GAAR)

• Prevents tax avoidance through aggressive planning.

• Applies to arrangements lacking commercial substance.

F. Controlled Foreign Corporation (CFC) Rules

• India does not currently have formal CFC rules, but GAAR and POEM (Place of Effective Management) rules serve similar purposes.

🔹 4. Double Taxation Relief in India

A. Unilateral Relief (Section 91)

• Given if there’s no DTAA, but foreign income is taxed in both countries.

B. Bilateral Relief (Section 90)

• Given when there is a DTAA. Relief can be by:

  • Exemption Method

  • Credit Method

Summary Table

       Tax Aspect                           Applies To                                     Relevant Provision

        Global Income              Residents (ROR)                                           Section 5

        Indian Source               IncomeNon-residents, Foreign Cos        Section 9

        Transfer Pricing            Associated Enterprises                               Section 92-92F

        Equalisation Levy        Non-resident digital companies              Section 165/165A

        Withholding Tax          Payments to non-residents                       Section 195DTAA

        Benefits                          Residents & Non-residents                        Section 90/90A

         Unilateral Relief           No DTAA but foreign tax paid                   Section 91

International Taxation

Expatriate Tax in India refers to the income tax rules and obligations that apply to foreign nationals (expats) working or staying in India. The tax treatment depends mainly on the residency status, type of income, and duration of stay in India.

📌 1. Residential Status – Key to Taxability

Under the Income Tax Act, 1961, an individual's tax liability depends on whether they are:

StatusCriteriaResident & Ordinarily Resident (ROR)Stayed ≥ 182 days in India during the financial year (April–March), or met other cumulative criteria.Resident but Not Ordinarily Resident (RNOR)Resident in India but hasn't been a resident in 2 out of the past 10 years, or stayed ≤ 729 days in past 7 years.Non-Resident (NR)Did not meet the 182-day or other residency conditions.

🔹 Tax Implication by Residency:

Type of IncomeRORRNORNRIndia-sourced incomeTaxedTaxedTaxedForeign incomeTaxedNot Taxed (mostly)Not Taxed

📌 2. Types of Income Taxed for Expats in India

If you're an expat working in India, you may be taxed on:

• Salary income (including perquisites like housing, car, etc.)

• Allowances (HRA, travel, education, etc.)

• Bonus/Commission

• Stock options (ESOPs)

• Reimbursements

• Other income like interest from Indian banks, capital gains on Indian assets

⚠️ Even if the salary is paid outside India, it is taxed if services are rendered in India.

📌 3. Tax Rates

Expats are taxed as per individual slab rates, same as Indian citizens:

Income Slab (FY 2025–26)Tax RateUp to ₹2.5 lakhNil₹2.5 – ₹5 lakh5%₹5 – ₹10 lakh20%Above ₹10 lakh30%

🔹 Surcharge and cess may apply for high earners.

📌 4. Double Taxation Avoidance Agreement (DTAA)

India has DTAA with over 90 countries (e.g., USA, UK, Germany, Australia). Benefits:

• Avoid double taxation on the same income

• Claim foreign tax credit for taxes paid abroad

• Choose between exemption method or credit method

📌 5. Social Security – Totalization Agreements

India has Social Security Agreements (SSA) with several countries. This helps:

• Avoid dual social security contributions

• Protect pension rights

Applicable countries include Germany, Belgium, South Korea, France, etc.

📌 6. Compliance Requirements for Expats

• PAN (Permanent Account Number): Mandatory for filing taxes

• Income Tax Return (ITR): File by July 31 (non-audit cases)

• Form 67: For claiming foreign tax credit

• Form 10F and Tax Residency Certificate (TRC): Needed for DTAA benefits

✅ Summary

       Aspect                                     Details

       Residency-based Tax               Yes – India taxes based on stay duration and source of income

       Global Income taxed?              Only if ROR

       DTAA                                             Available to avoid double taxation

       Tax filing                                      Mandatory if income > basic exemption

       PAN                                              Needed

Expatriate Taxation

Taxation litigation in India spans across various laws and authorities, involving both direct and indirect taxes. Here’s a breakdown of the major types of taxation litigations in India:

🔹 1. Direct Tax Litigations

These primarily involve Income Tax and are governed by the Income Tax Act, 1961.

Common types:

• Assessment Disputes
  Challenges to the tax amount assessed by the Income Tax Department.

• Transfer Pricing Disputes
  Issues involving pricing of international transactions between associated enterprises.

• Reassessment Proceedings (Section 147/148)
  Litigation over reopening of past assessments by the department.

• Search and Seizure Cases (Section 132)
  Disputes arising from raids and searches, especially regarding undisclosed income.

• Penalty Proceedings
  Cases contesting penalties for concealment or misreporting of income.

• TDS/TCS Issues
  Disputes on non-deduction, short deduction, or non-deposit of Tax Deducted at Source.

• Capital Gains Disputes
  Issues related to calculation, exemption, or classification of capital gains.

🔹 2. Indirect Tax Litigations

Indirect tax litigation involves taxes such as GST, Customs, and Excise.

A. Goods and Services Tax (GST) Disputes

Governing Law: Central Goods and Services Tax Act, 2017 and related state GST laws.

• Wrong Classification of Goods/Services

• Input Tax Credit (ITC) Disputes

• Anti-Profiteering Cases

• Mismatch in GSTR Filings

• E-way Bill and Detention Seizure Issues

• Transitional Credit Issues (from VAT/Service Tax to GST)

B. Customs Litigation

Governing Law: Customs Act, 1962

• Classification and Valuation Disputes

• Import/Export Restrictions

• Duty Drawback Disputes

• Evasion and Smuggling Allegations

• Misuse of Free Trade Agreements

C. Central Excise and Service Tax (Pre-GST Regime)

Though subsumed under GST, legacy disputes still exist.

• CENVAT Credit Disputes

• Classification of Goods/Services

• Show Cause Notices for Tax Evasion

🔹 3. Constitutional Litigation Related to Taxation

These are typically heard in High Courts and the Supreme Court under writ jurisdiction (Article 226/32).

• Challenge to Validity of Tax Laws

• Discrimination or Violation of Fundamental Rights by Tax Provisions

• Inter-State Tax Disputes

🔹 4. International Taxation Disputes

Involving cross-border transactions.

• Double Taxation Avoidance Agreements (DTAA) Interpretations

• Permanent Establishment Issues

• Equalisation Levy Disputes

• BEPS (Base Erosion and Profit Shifting) Concerns

🔹 5. Advance Rulings and Advance Pricing Agreements

• Authority for Advance Rulings (AAR): For clarity on tax liability of a transaction.

• Disputes from APA Interpretations in transfer pricing.

🔹 6. Appellate Proceedings and Forums

• CIT(A): Commissioner of Income Tax (Appeals)

• ITAT: Income Tax Appellate Tribunal

• CESTAT: Customs, Excise, and Service Tax Appellate Tribunal

• GSTAT: Goods and Services Tax Appellate Tribunal (being operationalised)

• High Courts and Supreme Court: On substantial questions of law

Tax based Litigation