Direct Tax and GST - Consultation, Compliance and Litigation
India's tax environment demands more than periodic filing. Businesses today face a continuous cycle of planning decisions, compliance obligations, and dispute management - often simultaneously. We provide an integrated practice across Direct Tax and GST that covers all three dimensions: advising before a position is taken, managing compliance so that exposure is minimised, and representing clients when disputes arise.
Consultation
Tax Planning and Advisory
Sound tax planning begins before a transaction is entered into, not after. We advise businesses and individuals on structuring transactions, investments, business arrangements, and corporate events in a manner that is tax-efficient, legally defensible, and aligned with commercial objectives. Our advice covers income tax, capital gains, withholding tax, and GST implications - ensuring that decisions are taken with full visibility of the tax consequences.
GST Advisory and Structuring
GST implications often determine how a transaction, supply chain, or business arrangement should be structured. We advise on questions of classification, exemption applicability, rate determination, place of supply, input tax credit eligibility, and the GST treatment of complex or multi-component transactions - giving businesses the clarity they need before contracts are signed and invoices are raised.
Business Restructuring and Transaction Advisory
Mergers, demergers, slump sales, business transfers, and group restructuring exercises carry significant direct tax and GST implications. We advise on the tax consequences of restructuring options, assist in structuring the transaction to achieve the desired outcome efficiently, and ensure that all applicable tax obligations arising from the restructuring are met.
Tax Due Diligence
For businesses acquiring or investing in another entity, understanding the target's tax position is critical. We conduct direct tax and GST due diligence reviews - identifying historical exposures, ongoing disputes, compliance gaps, and contingent liabilities - and provide a clear assessment of tax risk to inform investment and negotiation decisions.
Advance Ruling Applications
Where certainty on a specific tax position is required before a transaction is undertaken, we prepare and file applications for advance ruling before the Authority for Advance Ruling under GST and make representations before the Board for Advance Rulings under direct tax - ensuring that the ruling application presents the facts and legal question clearly and completely.
Opinions and Legal Positions
We provide written opinions on complex or contested questions of direct tax and GST law - covering interpretation of provisions, applicability of exemptions, treaty positions, and the sustainability of tax positions already taken. These opinions serve as documentation of professional advice and support the reasonable cause defence in penalty proceedings.
Compliance
Income Tax Return Filing
We prepare and file income tax returns for individuals, Hindu Undivided Families, partnership firms, LLPs, companies, and trusts - ensuring that income is correctly classified, deductions and exemptions are properly claimed, and returns are filed within applicable due dates. We also handle belated and revised returns, and manage advance tax computation and payment schedules to prevent interest exposure under Sections 448 and 449.
TDS Compliance
Tax Deducted at Source is one of the most operationally intensive compliance obligations for businesses. We manage the complete TDS function - computing deductions applicable to each payment category, ensuring timely deposit of TDS, preparing and filing quarterly TDS returns, issuing TDS certificates to deductees, and reconciling Form 26AS and AIS data to identify and resolve mismatches before they generate demands.
Tax Audit and Report Filing
We conduct tax audits under Section 63 and prepare and file the audit report in Form 3CA/3CB and 3CD - covering all required disclosures relating to income, expenses, loans, payments, and other specified matters. We also prepare and file other audit reports and certificates required under the Income-tax Act, 2025 including Forms 3CEB for international transactions, 10B for charitable trusts, and others applicable to the client’s profile.
GST Registration
We assist businesses in obtaining GST registration - covering normal registration, composition scheme registration, registration for e-commerce operators, casual taxable persons, and non-resident taxable persons. We also manage amendments to registration particulars and advise on the requirement to obtain separate registrations for multiple states.
GST Return Filing
We prepare and file the complete suite of GST returns - GSTR-1 for outward supplies, GSTR-3B for monthly tax payment and summary, GSTR-9 annual return, and GSTR-9C reconciliation statement - ensuring that returns are accurate, filed on time, and reconciled with books of account and e-way bill data to prevent mismatches that attract departmental scrutiny.
Input Tax Credit Reconciliation
ITC reconciliation between GSTR-2B and books of account is a critical and ongoing compliance activity under GST. We perform monthly ITC reconciliations, identify mismatches arising from supplier filing gaps, and take timely corrective action - ensuring that ITC is availed correctly and that the risk of disallowance is minimised.
GST Annual Return and Audit
We prepare and file GSTR-9 and GSTR-9C for clients whose turnover exceeds the prescribed threshold - reconciling tax paid during the year with annual figures, identifying and disclosing short-paid tax, and certifying the reconciliation statement where required. We also assist in responding to queries arising from annual return filing.
E-Invoicing and E-Way Bill Compliance
We assist businesses in implementing e-invoicing under the IRP framework, managing e-way bill generation and compliance, and ensuring that transactional documentation meets the procedural requirements of GST law - reducing exposure to detention proceedings and input tax credit disallowances arising from documentary deficiencies.
Litigation
Notices and Departmental Communications
Litigation most commonly begins with a notice. Whether it is a scrutiny notice under Section 170(2), a reopening notice under Section 188 or 188A, a query letter under Section 168(1), a summons under Section 247, or a show cause notice under the GST law - each communication carries specific procedural obligations and timelines. We review every notice, assess its implications, and prepare responses that are legally precise, factually complete, and submitted within the time allowed.
Assessment and Scrutiny Proceedings
We manage the complete assessment process before the Assessing Officer - organising documentation, drafting written submissions, attending hearings, and ensuring that every query is addressed with clarity and evidentiary support. Our focus at the assessment stage is to prevent unjustified additions and disallowances before they crystallise into demand.
First Appeals - CIT(A)
Where assessments result in additions or demands that are not sustainable, we prepare and file appeals before the Commissioner of Income Tax (Appeals) or Joint Commissioner (Appeals) - building a strong factual and legal case for each ground of appeal supported by judicial precedents, CBDT circulars, and Tribunal decisions.
Income Tax Appellate Tribunal (ITAT)
We represent clients before the ITAT on complex matters involving business income, capital gains, disallowances, unexplained credits, and international tax questions - preparing detailed paper books, written submissions, and presenting arguments before the Bench.
GST Adjudication and Appeals
We represent clients through GST adjudication proceedings and file and argue appeals before the Appellate Authority under Section 107 of the CGST Act - and before the GST Appellate Tribunal as it becomes operational across jurisdictions.
Search, Survey, and Special Proceedings
Post-search assessments under Section 292 and proceedings arising from GST inspections and searches under Section 67 require specialised handling. We assist clients in managing such proceedings from initiation through assessment - advising on disclosure obligations, preparing responses, and contesting additions that are not supported by evidence or law.
Penalty, Prosecution, and Compounding
We handle penalty proceedings under direct tax and GST - contesting penalties wherever the facts and law support it, filing applications for immunity and compounding where appropriate, and responding to prosecution notices where they arise.
Refund Disputes and Recovery Proceedings
We pursue refund claims rejected by the department under both direct tax and GST, file appeals against rejection orders, and represent clients in recovery proceedings - ensuring that legitimate refunds are recovered and that coercive recovery action is stayed pending resolution of disputes.
Rectification, Revision, and Stay Applications
We file rectification applications under Section 386, revision petitions under Sections 263 and 264, and stay applications before the AO, CIT(A), and ITAT - protecting clients from demand recovery while disputes remain under contest.