Income Tax Advisory, Notices & Planning

Professional Income Tax Dispute Resolution & Planning

Managing direct tax liabilities requires a balance between proactive tax planning and structured dispute resolution. With the introduction of the Faceless Assessment Scheme by the Central Board of Direct Taxes (CBDT), interacting with the Income Tax Department has transitioned to a fully digital, document-driven process. We provide direct tax advisory, representing corporate and individual clients in tax disputes and assessments.

Our tax litigation team prepares structured submissions, drafts technical responses to tax notices, and represents client positions before tax authorities, protecting businesses from arbitrary tax demands.

Dissecting Income Tax Notices

Receiving an official tax notice requires a technical review of the statutory section under which it has been issued:

• Section 143(2) Scrutiny Notice: Issued when a tax return is selected for detailed audit. The taxpayer must submit documentary evidence (such as bank summaries, ledger books, and transaction records) to support their claims.
• Section 148 (Reassessment): Issued when the assessing officer has "reason to believe" that taxable income has escaped assessment. This requires a thorough review of past records and compiling detailed direct tax justifications.
• Section 156 (Demand Notice): Demands payment of outstanding taxes, interest, or penalties determined during assessments. We review the calculations and file rectification applications u/s 154 if discrepancies exist.

Appeals & Faceless Representation

If an assessment results in unfair additions or disallowances, we assist clients in filing appeals:

1. CIT(Appeals) Filings: Preparing Statement of Facts and Grounds of Appeal in Form 35, and presenting technical submissions in faceless appellate hearings.
2. Penalty Defense: Preparing replies to show-cause notices for levy of penalties under Section 270A (for under-reporting or misreporting of income).

Capital Gains Tax Optimization & NRI Advisory

We advise on optimizing capital gains taxes resulting from property sales, asset transfers, or business sales:

• Section 54 & 54F Exemptions: Guiding clients on reinvesting capital gains from residential or non-residential assets into new residential properties within statutory timeframes.
• Section 54EC Bonds: Coordinating investments in specified infrastructure bonds (REC, NHAI, PFC) within 6 months of sale to claim tax exemptions (up to ₹50 Lakhs per financial year).
• NRI Taxation u/s 195: Helping non-residents secure lower tax withholding certificates (Form 13) for property sales, and advising on Double Taxation Avoidance Agreements (DTAA) and Tax Residency Certificates (TRC).