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Corporate & International Taxation

OVERVIEW

Corporate tax assessments and appeals, cross-border structuring, treaty interpretation, and transfer pricing — advisory and dispute support for domestic and international clients.

EXPERTISE

What We Do

Corporate Tax Litigation

Representation before assessing authorities, the CIT(A), ITAT, and the higher courts on corporate tax positions.

International Tax Structuring

Advice on cross-border transactions, treaty eligibility, and permanent establishment exposure.

Transfer Pricing & APAs

Benchmarking positions, audit representation, and support through the Advance Pricing Agreement process.

Withholding Tax & Treaty Interpretation

Advisory on withholding obligations and interpretation of India’s tax treaties for inbound and outbound structures.

KEY AREAS

Income Tax • International Taxation • Transfer Pricing

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Our Approach

Our advisory and dispute work are handled by the same team, so structuring advice is shaped from the outset by how a position would need to be defended before an assessing officer, the ITAT, or in treaty arbitration — not just how it reads on paper.

Representative Experience

01. Advised a listed manufacturing company on cross-border restructuring and treaty eligibility for an outbound investment.

02. Represented a technology company in transfer pricing audit proceedings involving intra-group service charges.

03. Advised a private equity fund on the tax structuring of an inbound investment into an Indian portfolio company.

4. Represented a corporate group before the ITAT in an appeal concerning permanent establishment exposure.

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