Tax, Licence & Approvals
Tax Advocates & Consultants
Tax work divides into two halves that need each other: taking a defensible position before a transaction happens, and defending it afterwards when the department asks. We do both.
The ground
What you are actually dealing with
What a notice actually means?
Not every communication from the department is an accusation. A section 143(1) intimation is an arithmetic check. A 143(2) notice opens scrutiny. A 148 notice reopens an assessment and carries its own limitation and procedural requirements, several of which are frequently not met. Reading which one has arrived, and what it permits the officer to do, determines the whole response.
The appeal ladder
An assessment order is not the end. Appeal lies to the Commissioner (Appeals), then to the Income Tax Appellate Tribunal on questions of fact and law, then to the High Court and Supreme Court on substantial questions of law alone. Each rung has its own limitation period, and each is far easier to use if the record was built properly at the assessment stage rather than reconstructed later.
The record is made early
Most tax disputes are won or lost on documentation created long before the notice: the contemporaneous agreement, the board resolution, the valuation, the correspondence that shows why a thing was done. A position taken with the paperwork in place is defensible. The same position taken without it is an argument.
Our part
How we run tax matters
The practice runs on the litigation end as well as the advisory end, which changes the advice. Knowing what an officer will ask for, and what a Tribunal will accept, is what makes a pre-transaction opinion useful rather than decorative.
- 01
Responses drafted to the specific provision invoked, not as a general explanation.
- 02
Procedural defects in reassessment and penalty proceedings identified and taken.
- 03
Appeals prepared with the record as it should have been built, and grounds framed to survive.
- 04
Advisory work documented so the file supports the position years later.
Scope
What this engagement covers
- Scrutiny assessment and reassessment representation
- Appeals before CIT(A) and the Income Tax Appellate Tribunal
- GST assessments, audits and departmental proceedings
- Penalty and prosecution defence
- Advisory on transactions, structuring and tax positions
- Rectification, refunds and stay applications
How it runs
The process, stage by stage
No stage carries a promised date. The Registry's queue and the court's list are not ours to commit on your behalf. What we commit to is doing our part of each stage without delay.
- 01
Read the notice
The provision invoked, the limitation position and what the officer is actually permitted to examine are established first.
- 02
Build the record
Documents, agreements and contemporaneous material are assembled, and gaps identified while there is still time to explain them.
- 03
Respond
A reply is drafted to the specific provision, with the material annexed, and hearings attended.
- 04
Appeal where required
Grounds are framed against the order as passed, and the appeal filed within limitation with a stay application where recovery is pressing.
- 05
Advise forward
Whatever the outcome teaches about the business's positions is fed back into how the next year is documented.
Common questions
Questions we are asked most often
Urgent enough to read the same day. Every notice carries a response period, and several carry consequences for silence: including assessment on a best-judgement basis, which is far harder to undo than to prevent.
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