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Tax, Accounting & Finance

Direct Tax Advisory — Structure First, File Second

Tax is not a filing — it's a design discipline. The structures you choose, the elections you make, the documentation you keep: these determine your tax outcome far more than the return itself. We advise on corporate tax structurally, defend assessments vigorously, and keep you out of disputes that planning would have prevented.

22%vs 30% — regime elections modelled, not guessed
Assessmentto appeal — full dispute lifecycle
TPtransfer pricing documentation & defence
Writtenopinions before transactions, not after

What is direct tax advisory, in plain words?

Direct tax advisory covers income-tax as it applies to companies: tax planning and structuring (which regime, which entity, which transaction form), compliance (advance tax, TDS, returns), assessment proceedings (scrutiny, reassessment), appeals (CIT(A), ITAT, High Court), and international tax including transfer pricing and treaty analysis.

The discipline runs on a simple principle: tax outcomes are determined when transactions are structured, not when returns are filed. Every advisory engagement we do is really about moving the decision point earlier — where the options are still open.

How do you know you need this?

Signal 01

Companies making structural decisions — new ventures, expansions, acquisitions, group reorganisations — where the tax-efficient form differs from the obvious form and the difference is measured in crores. Profitable companies choosing between tax regimes, where the election is irrevocable and the modelling has to be right.

Signal 02

Companies in scrutiny or reassessment — where the quality of response determines whether the proceeding closes or escalates. And groups with cross-border transactions, where transfer pricing documentation isn't optional and treaty positions need defending.

What we actually do.

1

Tax structuring

Transaction and entity structuring for tax efficiency — mergers, demergers, fundraises, exits, cross-border flows. Designed with commercial reality first and tax optimisation within it, documented to survive scrutiny. The best tax planning is invisible in the financials and unassailable in assessment.

2

Regime and election advisory

115BAA vs old regime modelling, MAT credit analysis, section elections — computed on your actual numbers, not rules of thumb. Irrevocable elections deserve revocable-quality analysis before they're made.

3

Assessment and reassessment defence

Scrutiny notices answered with precision: submissions drafted, hearings attended, positions defended with case law. We treat assessments as advocacy, not correspondence — because that's what they are.

4

Appeals

CIT(A), ITAT, and High Court — grounds drafted, paper books prepared, counsel briefed. Appeals are won on the quality of the grounds and the completeness of the record; we build both.

5

International tax and transfer pricing

Treaty analysis, PE exposure, withholding positions, TP documentation (master file, local file, CbCR), and benchmarking. Cross-border tax is a specialty; we treat it as one.

What it costs, and how long it takes.

How long it takes

Advisory retainers for ongoing structuring questions; fixed fees for assessments, appeals, and TP documentation — each quoted on complexity. A scrutiny response and an ITAT appeal are different assignments with different economics.

What it costs

Timelines follow the department's: assessments run their statutory course, appeals take 1–3 years per forum. We manage the process; we don't promise to accelerate the tribunal.

Where we see this go wrong.

Watch out

Structuring after the transaction

Asking for tax advice after the deal is signed. The efficient structure was available before; after, you're doing damage control. The advisory calendar should lead the transaction calendar.

Watch out

Regime election by thumb-rule

Choosing 115BAA because "everyone does" without modelling MAT credits, exemptions, and future projections. We've seen companies pay more under the "lower" rate. Model, don't follow.

Watch out

Weak assessment responses

Vague replies to scrutiny notices that invite further inquiry. Every response is either closing the proceeding or opening new ones — there's no neutral. Precision matters.

How the engagement works.

Step 01

Understand

Facts, documents, and the real question — tax advice on wrong facts is worse than no advice.

Step 02

Analyse

Provisions, case law, treaty positions. Options with consequences, quantified.

Step 03

Advise

Written opinion or structuring memo — the recommendation with its reasoning and risks.

Step 04

Defend

Assessments, appeals, TP proceedings — advocated through to resolution.

Questions we hear.

It depends on your MAT credit position, exemptions, and projections. We model both regimes on your numbers — the answer is arithmetic, not fashion.

Don't panic, don't ignore. We review the notice, gather the position papers, and respond precisely. Most scrutinies close with a good response.

If you have international transactions with associated enterprises above thresholds, yes — master file, local file, and accountant's report. Non-compliance penalties are severe.

CIT(A): 1–2 years typically. ITAT: 1–3 years. High Court longer. We manage expectations honestly and the process diligently.

Yes — jurisdictional challenges where available, and merits defence where not. Reassessment has strict legal preconditions; we test them first.

We coordinate it — advance tax, TDS, returns — usually alongside our accounting team. Advisory and compliance together is where the value compounds.

When the position is debatable, yes — disclosure avoids penalty even if the addition sustains. Silence on grey areas is what converts tax into penalty.

Comparability analysis, functional benchmarking, and documentation that predates the notice. TP defence is won in the documentation year, not the assessment year.

Yes, within the statutory window — revised returns are normal, not suspicious. What invites scrutiny is revising to manufacture losses.

Mismatches — between returns, TDS statements, GST filings, and information returns. The department's systems find inconsistencies before officers do.

Tax, Accounting & Finance

Start with a conversation.

Talk to a partner about your situation — no pitch, no obligation. If we're not the right firm for it, we'll tell you that too.

Request a consultation