Direct Tax

Representative Matters

• A host of cross border taxation issues, for both, inbound as well as outbound investments.
• Structuring international transactions in the most tax efficient manner to minimize tax incidence.
• Drafting and reviewing transaction documents in cross border transactions from a tax perspective.
• Conducting transfer pricing in transactions between associated enterprises to benchmark the value of the transaction against Arm’s Length Price to be charged.
• Representing clients in transfer pricing proceedings and assisting in the preparation of Transfer Pricing documentation to ensure compliance of the Transfer Pricing Regulations.
• Representing clients in mutual agreement procedures, invoked before domestic and overseas tax authorities, as an alternative to tax litigation.
• Evaluating tax exposures under domestic tax legislation and providing holistic advisory services with respect to all domestic tax issues.
• Guiding clients in respect of special tax regimes such as SEZ, STPI, EOU, EPZ, etc., to help with clients’ decision making process of establishing operations in India.
• Preparation and filing of corporate tax returns, withholding tax returns and all other such statutory tax compliances.
• Rendering advice on structuring of remuneration packages of expatriate employees.
• Structuring foreign investments into India, including on establishment of intermediary investment vehicles in tax friendly jurisdictions.
• Advised American Airlines on customs, trade and regulatory laws in India, including customs classification, and import conditions related to various aircraft items, parts, and accessories required to commence business operations from India.
• Represented Travelport Inc. and Travelport Distribution System BV in a SLP before the Supreme Court of India by Revenue to contest the issue of attribution of profit to the permanent establishment (PE) of Travelport in India and for allocation of additional profits to the alleged PE of Travelport in India.
• Successfully obtained the regulatory approvals from Special Economic Zone and tax authorities for Singapore Exchange Limited (SGX) India Connect IFSC Private Limited, a special purpose vehicle of SGX at Gujarat International Finance Tec-City (GIFT City).
• Advised a global pharmaceutical major in the merger of two of its listed subsidiaries.
• Advised a leading trader of medical diagnostic equipment’s on a number of direct tax related issues.
• Successfully obtained the renewal of the Special Valuation Branch (SVB) order issued to Louis Vuitton Retail India Private Limited from the customs authorities.
• Advised a multinational high-technology group specializing in photo sensor technology in structuring the transaction of supplying equipment’s and upgradation of technology to the Ministry of Defence Enterprise for manufacturing of high-end defence products for the purpose of supply to the Indian Army.
• Advised an Australian University in its proposed franchisee arrangement with an Indian educational institution.
• Advised entities like RAS GAS, Petronet LNG, etc. on various direct tax related issues.
• Advised on the tax implications in connection with the proposed joint venture between a leading Indian Company (with its presence in various industry sectors) and a major coffee company having a worldwide presence for setting up retail outlets.
• Advised one of the leading Indian listed companies operating in the entertainment sector to acquire state of the art theatre systems from a reputed global manufacturer.
• Advising a leading infrastructure group including representing it before tax authorities. Successfully contested an appeal before the Income Tax Appellate Tribunal in the client’s claim of depreciation.
• Advising a leading publicly traded third party Business Process Outsourcing Service Provider in all its tax matters since inception including representation before the tax authorities and appellate authorities.
• Advising a leading US University in its proposed joint venture with an Indian healthcare group.
• Advising a major Britain headquartered multi-national corporation on all its tax matters and representation of the client before tax authorities and appellate authorities.
• Advising and representing a large third party Business Process Outsourcing Service Provider since inception in all its tax matters and litigations.
• Advising one of the largest luxury goods providers on a number of direct tax related issues including matters pertaining to transfer pricing and representation before tax and appellate authorities.
• Assisted a leading scheduled commercial airline with tax structuring in connection with the acquisition of aircraft.
• Assisted a major media company in structuring its overseas private placement to a US entertainment and media conglomerate.
• Assisted an Indian infrastructure major in the acquisition of an overseas coal mine.
• Assisted many multi-national corporations who were rendering services and making supplies to major oil and natural gas exploration entities like ONGC, GSPC, etc.
• Assisted various leading private equity funds in structuring investments in Indian investee entities.
• Providing advisory services to a major investment company in relation to divestment of its stake in Indian companies.
• Rendering ongoing advisory services to a leading private equity fund on matters including group re-structuring.
• Rendering ongoing advisory services to leading private equity funds on matters including fund structuring, management company structure, establishment of Indian advisory entity, etc.
• Represented a leading domestic FMCG company in the search proceedings initiated against it, successfully contested the case at appellate authority level. Also rendered advisory services to the client on various direct tax matters.
• Advising a leading Indian Infrastructure Group on structuring of tax for not for profit initiatives undertaken by it.
• Successfully represented a leading Indian fast food company before the appellate authorities and obtained positive rulings and advised it on various domestic and international tax issues pertaining to its overseas forays.
• Successfully represented an Indian Listed Infrastructure Company before the appellate authorities and obtained positive rulings. Also advised the company on a number of direct tax issues on a regular basis.