Services
Pre-transaction modeling, entity optimization, and appellate defense for enterprises and high-net-worth individuals — treating tax liability as a controllable expense, not a year-end surprise.
What you get
Tax liability is not an inevitability — it is a function of structure, timing, and documentation. Businesses and individuals who engage a tax advisor only at year-end are paying for history: the deal has closed, the year has ended, and the planning options that were available in October have expired. Those who manage their effective rate systematically engage before the transaction closes, before the assessment notice arrives, and before funds cross a border.
This practice operates across three mandates that most firms handle separately: proactive entity and transaction planning to minimize what is legally owed; cross-border and DTAA advisory to prevent double taxation and clear international remittances; and appellate defense when the department takes an adverse position. The same team that engineers the structure defends it if challenged.
Engagement outcomes
Effective rate reduction
9.7pp
Typical outcome from Sec 115BAA transition plus MAT credit optimization for mid-size domestic companies.
Assessment response filed
Day 15
Ground-wise, evidence-backed response to scrutiny or Sec 148 notice — within 15 working days of receipt.
Capital gains saved
40–60%
Via pre-transaction Sec 54 series modeling on high-value real estate and unlisted equity sales.
The structural difference
The filing-only model
Our approach
The scope of a strategic tax engagement depends on where the client sits in the tax lifecycle. For a company considering the Sec 115BAA transition, the work is primarily analytical — modeling taxable income forward and computing the MAT credit forfeit. For a promoter group with a pending property sale, it is pre-transactional. For a company under Faceless Assessment, it is defensive. Each of the six areas below operates as a self-contained mandate or as part of a year-round advisory retainer.
Practice areas
Effective rate engineering for domestic companies: Section 115BAA/BAB concessional regime transitions, MAT credit modeling, depreciation scheduling, and structuring promoter and director profit extraction to minimize aggregate tax across entities.
Pre-transaction modeling for residential and commercial property, unlisted equity, and business asset sales. We map the full Sec 54 / 54F / 54EC exemption chain and time the transaction to maximize the legal offset before the sale deed is registered.
Cross-border remittance structuring, Form 15CA/CB certification, treaty benefit claims under India’s 95+ DTAA agreements, and transfer pricing studies satisfying Sec 92D arm’s-length documentation requirements for related-party transactions.
Ground-wise responses to Sec 143(3) scrutiny notices and Sec 148 reassessment proceedings. We build the evidentiary dossier before the AO’s deadline and engage directly through the Faceless Assessment portal without requiring the client to appear.
When the Assessing Officer sustains an addition, we escalate without delay. CIT(A) appeal memos are prepared with full documentary evidence; ITAT briefs are drafted to the standard required for written submissions and oral argument before the Tribunal.
Crisis representation for Sec 132 search and Sec 133A survey proceedings. We protect promoter statements, organize the documentary record in the hours immediately following, and manage the intense post-search assessment that follows over the next 24 months.
A tax position defended years later is only as strong as the documentation written on the day the decision was made.
The planning mandate suits domestic companies with taxable income above ₹1 crore, promoter groups with inter-entity complexity, and individuals with recurring capital gains events — real estate churn, ESOP liquidations, or private equity exits. The appellate practice handles any company or individual that has received a scrutiny notice, Sec 148 reassessment, or adverse CIT(A) order, regardless of size or revenue.
Companies that have not formalized the transition to Sec 115BAA, are accumulating MAT credits they may not fully utilize, or have inter-company transactions without arm’s-length documentation. The effective rate reduction alone typically covers the advisory cost within the first year.
Business families with multiple entities, real estate portfolios, and succession considerations. Planning covers estate freezing via HUF and trust structures, capital gains timing across financial years, and wealth extraction structured to minimize dividend distribution exposure at the corporate level.
Any entity with related-party cross-border transactions, foreign subsidiary dividends, or royalty and management fee flows needs transfer pricing documentation and withholding tax planning. The penalty for non-compliance starts at 2% of transaction value under Sec 271G — the study cost is a fraction of that.
If a notice has already arrived, the response window is narrow — AO deadlines are typically 15–30 days. We take on Faceless Assessment mandates mid-stream and have reversed adverse AO orders at CIT(A) in over 90% of matters handled to date by presenting evidence the original filing did not include.
Methodology
Review of your current effective tax rate, entity structure, historical ITRs, and open assessments. We identify the three highest-leverage optimization levers and any existing exposure before recommending any action.
For pre-transaction mandates — property sales, M&A, restructuring, or capital raises — we model the tax outcome under multiple structuring options before any documents are signed. This is where most of the value is created.
Filing elections (Sec 115BAA, Sec 54, Sec 195 withholding positions), submitting Form 15CA/CB, registering the trust or LLP, or completing the slump sale — executed with a documented audit trail at each step.
Every position taken is backed by a written legal opinion, cited to Income Tax Act sections and judicial precedents. Transfer pricing studies, 3CD certificates, and advance ruling applications are prepared to the same standard.
When a notice arrives — scrutiny, Sec 148, or search — we build the evidentiary dossier, draft the response, and appear before the Assessing Officer, CIT(Appeals), and ITAT. The same team that planned the structure defends it.
Scope
Common questions
Explore further
Structured planning for residential and commercial property sales. We model Section 54, 54EC, and 54F exemptions before the deed is signed — eliminating or substantially reducing your capital gains liability.
Learn moreEnd-to-end compliance for non-residents selling Indian property or transferring funds abroad — Lower TDS Certificates under Section 197, Form 15CA/15CB clearance, DTAA relief, and NRI income tax returns.
Learn moreStatutory tax audit under Sec 44AB — programmatic ledger reconciliation, zero-variance Form 3CB-3CD, and on-time IT portal filing. Office in Kharar; pan-India clients served remotely.
Learn moreNext step
Book a 30-minute discovery call. We'll scope the engagement, confirm deliverables, and give you a fixed-fee proposal within 48 hours.