Tax

We have a strong tax practice that draws on the expertise of our multidisciplinary team of lawyers. We understand the complex legal aspects of direct and indirect taxation, and specific issues that emanate from an evolving tax environment. Given the interplay of tax law with other regulatory regimes, especially those impacting the commercial aspects of businesses, we advise clients in line with their specific business needs. We regularly advise clients on several direct and indirect taxation areas, such as tax advisory, tax controversy, due diligence, advance pricing agreements, M&As, international tax and transfer pricing structuring and controversies, advance rulings, appeals, and prosecution and litigation.

We work with the tax, finance and legal teams of major domestic and multinational companies on an array of issues, such as structuring foreign investments and joint ventures, tax implications on EPC and tariff-based projects, business transfers, import and export of raw material, capital goods, finished goods and services, and supply chains.

Our team has expertise in taxation benefits available for infrastructure projects, and schemes such as special economic zones, export-oriented units, and software and technology parks. Our Partners regularly advise on benefits under export-based or promotional schemes. We also advise on the tax implications of investment by foreign direct and institutional investors in equity and non-equity securities, such as foreign currency convertible bonds. We work closely with the Government on strategies relating to Central and State taxes.

Our lawyers are highly rated by reputed institutions such as Chambers & Partners, Legal 500, ALB, and the International Tax Review. Our team members bring diverse experience, having previously worked with well-known law firms and the Big Four accounting firms.

Select Representative Experience/Clients

• PJSC Cryogenmash​, on complex issues of permanent establishment risks on service arrangements involving construction and supervision for establishing Fluid Servicing System as part of a government project in India
• Agusta Westland​, on PE risk and personal taxation issues upon secondment of employees to India
• Macnica, on various tax issues pertaining to Macnica’s acquisition of CrowdAnalytix from various Mauritian funds​
• GE India​, on tax-related aspects of a proposed business restructuring endeavor among several of GE’s group companies, which includes advice on mergers, consolidation of holdings at various levels, and so on​
• Boeing,​ on tax and regulatory changes required under various statutes to incentivise aircraft financing entities to set up operations in India
• Airbus,​ on conducting full-scale tax due diligence and provided advice in relation to an acquisition of a major MRO operator in India​
• Philips India, on the acquisition of CG Glass, a listed company, from the Crompton Greaves Group, conducts comprehensive due diligence and advising on transaction structuring, documentation, direct and indirect taxation and liability issues
• MTR Foods Pvt Ltd, on conducting a vendor due diligence from a tax perspective
• Samsung Electronics Corporation, Korea,​ before the High Court to defend the favourable order of the ITAT wherein it was held that there is no Permanent Establishment of Samsung in India
• Exxon Mobil,​ before the ITAT, in a dispute involving the deductibility of certain business expenses
• AT Kearney India Pvt Ltd, before ITAT involving the issue of allowability of 10A deduction on voluntary transfer pricing adjustment and other corporate tax issues
• LinkedIn India,​ before the ITAT in a transfer pricing dispute on the determination of arm’s length price of market support services provided by the Indian captive entity
• Negotiation of unilateral and bilateral APA of US and European companies, on issues relating to profit split among group companies, justification of intra-group charges based on allocation keys, valuation of intangibles and business restructuring ​
• BG Exploration and Production India​, on a continuing sales tax dispute regarding the sale of crude/natural gas and its impact on the proposed exit
• Japan Bank for International Cooperation, on tax implications on aircraft finance, leasing of dredging ships in India. Also advised on tariff and non-tariff incentives for exporters in India WTO sanctions and implications thereon
• Energy Efficiency Services Ltd, on VAT demands in the State of Andhra Pradesh​
• Tata Communication Ltd, in DRI proceedings and before the settlement commission in a classification dispute​

Our Team

• 

  Himanshu Sinha

  Tax

• 

  Komal Dani

  Tax

• 

  Meyyappan Nagappan

  Tax, Environmental, Social, and Governance (ESG)

• 

  Samsuddha Majumder

  Tax