Tax Litigation Advisory

1. Income Tax Litigation

  • Replying to notices under Section 139(9), 142(1), 143(2), 148, 245, etc.

  • Representation before Assessing Officer, CIT (Appeals), and ITAT

  • Handling scrutiny, reassessment, and best judgment assessments

  • Filing of appeals, stay petitions, and rectification requests

  • Defence in search, seizure, or survey cases

 

2. GST Litigation & Representation

  • Response to GST show cause notices, DRC-01/DRC-07 demands

  • Assistance during departmental audits, anti-evasion actions

  • Representation before GST Officers, Appellate Authorities, and AAR

  • Disputes related to ITC reversal, classification issues, and mismatches

  • Filing appeals before appellate forums and tribunals (as operational)

 

3. TDS/TCS Litigation Support

  • Resolution of demands and notices under Sections 201, 234E, 271H

  • Assistance with short deduction, late payment, and interest penalties

  • Reply to CPC-TDS or TRACES-generated defaults

  • Support in revision of TDS returns and PAN mismatch corrections

  • Representation in TDS survey or audit proceedings

 

4. International Tax & Transfer Pricing Disputes

  • Advisory and defence on foreign remittance-related disputes

  • Representation for Form 15CA/CB, DTAA or foreign income issues

  • Support in Transfer Pricing adjustments and disputes (Form 3CEB)

  • Representation in proceedings involving non-resident taxation

  • Assistance in MAP, APA, or DRP procedures

 

5. Appellate Proceedings Support

  • Preparation and filing of appeals with:

    • CIT (Appeals)

    • Income Tax Appellate Tribunal (ITAT)

    • GST Appellate Authority

  • Drafting of Statement of Facts, Grounds of Appeal, and legal submissions

  • Condonation of delay petitions, stay on demand applications

  • Liaison with legal counsel for High Court/Supreme Court matters (if needed)

 

6. Legal Drafting & Documentation

  • Drafting replies to notices, reassessments, and show cause letters

  • Preparing affidavits, rejoinders, and audit responses

  • Summarizing case files for advocate briefing

  • Review of orders and assistance in seeking rectification or revision

 

7. Search, Seizure & Survey Proceedings

  • Assistance during search (Sec 132), survey (Sec 133A), or summons

  • Legal support during seizure of documents and statements

  • Post-search compliance: income disclosure, penalty mitigation

  • Preparation for post-search assessment proceedings

 


8. 📅 Typical Tax Litigation Timeline

Stage

Time Frame

Notice Reply

7–30 days

Assessment Proceedings

1–3 months

Appeal to CIT(A)

6–12 months

ITAT/Tribunal Appeal

12–24 months