The tax environment is increasingly complex making the management of tax risk, controversies and ultimately their resolution increasingly important but this is placing an additional burden on tax functions and taxpayers which can be costly, time consuming and can impact your reputation. With the surge in tax risks, complex rules and regulations, interagency cooperation and real time communication between tax authorities there is an increasing emphasis on evidencing behaviours through governance and documentation. Technical merit is no longer enough. Our team can help you manage your disputes strategically, efficiently, fairly and with reduced risk to your reputation in the following areas:
- Assisting in filing appeals and representation before the aforesaid appellate authorities namely Dispute Resolution Panel (DRP), Commissioner of Income Tax (Appeals), Income Tax Appellate Tribunal (ITAT) and complying with appellate requirements and procedures
- Assisting in determining the appeal strategy and approach and preparing of tax submissions
- Advising on the course of action to be adopted before revenue authorities to mitigate the risk of penal consequences
- Reviewing pending litigation and other uncertain tax positions, to comment on adequacy of defence, probability of success and prevention of recurrence
- Assisting in relation to the above areas in coordination with external legal counsel authorised to represent clients before High Courts
- Assistance in Mutual Agreement Procedure (MAP) wherein we prepare MAP application and filing the same with the competent authority. We also assist our clients in analyzing the resolution and assisting them in taking final decision on the same.
- Assistance in developing strategies and guiding through the process of Advance Pricing Agreements (APAs) to help ensure successful outcomes; resolving bilateral disputes