Category: Tax Advisory & Notice Management

1. Tax Advisory Services

Tax Advisory involves providing expert advice on complex tax matters to help clients structure their transactions, business operations, and investments in a tax-efficient and legally compliant manner. The goal is often to minimize tax liabilities while mitigating the risk of penalties and legal issues.

Key Areas of Tax Advisory:

• Corporate Tax Planning: Advising on optimal business structures, utilization of deductions and exemptions, capital gains planning, and tax implications of corporate decisions (e.g., mergers, acquisitions, restructuring).
• International Taxation: Providing guidance on cross-border transactions, tax treaties (Double Taxation Avoidance Agreements – DTAAs), Permanent Establishment (PE) issues, and repatriating profits.
• Transfer Pricing (TP): Assisting multinational companies with establishing, documenting, and defending pricing for transactions between associated enterprises. This ensures these transactions are conducted at an “arm’s length” price, as required by law. Services include TP documentation, strategizing, and dispute resolution (e.g., Advance Pricing Agreements – APA).
• Indirect Tax Advisory (e.g., GST in India): Offering consultancy on the applicability, classification, valuation, input tax credit (ITC) eligibility, and compliance requirements under Goods and Services Tax (GST) laws.
• Regulatory & Compliance Consulting: Advising on compliance with other tax-related regulations, such as Foreign Exchange Management Act (FEMA) for foreign investments and transactions.
• High-Net-Worth Individual (HNI) Advisory: Tailored tax planning for affluent individuals and family enterprises, covering wealth management, succession planning, and estate tax considerations.

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2. Notice Management Services

Notice Management focuses on proactively and reactively handling all official communication, inquiries, intimations, and notices received from tax authorities (like the Income Tax Department or GST authorities). Timely and accurate responses are critical to avoiding unfavorable assessments, penalties, and litigation.

The Notice Management Process:

1. Receipt and Analysis:
   • Verification: Authenticating the notice (e.g., checking the Document Identification Number – DIN) to ensure it’s genuine.
   • Understanding: Carefully analyzing the notice to identify the issuing section of the law (e.g., Section 139(9) for defective return, Section 143(2) for scrutiny, Section 156 for tax demand), the specific query, the required documents, and the deadline.
2. Documentation and Response Drafting:
   • Gathering Evidence: Collecting all relevant supporting documents (e.g., bank statements, Form 26AS, Form 16/16A, investment proofs, invoices) as requested in the notice.
   • Drafting Reply: Preparing a clear, precise, and well-supported legal and factual response that addresses every point raised by the tax authority.
3. Submission and Follow-up:
   • Online Submission: Submitting the response and supporting documents through the official e-filing portal within the stipulated time.
   • Follow-up: Tracking the status of the response and preparing for subsequent interactions, such as attending hearings (in-person or virtually, as in the Faceless Assessment/Appeal regime in India).
4. Dispute Resolution and Litigation Support:
   • If a tax notice results in an adverse order or demand, advisors provide support in appeals before appellate authorities (e.g., Commissioner of Income Tax (Appeals) – CIT(A), Income Tax Appellate Tribunal – ITAT) and high courts.

Common Types of Notices in India:

Section	Type of Notice	Purpose
139(9)	Defective Return	Asking the taxpayer to rectify errors in a filed return.
143(1)	Intimation	An intimation after processing the return, confirming the tax/refund amount, or raising a preliminary demand.
143(2)	Scrutiny Notice	Official selection of a case for a detailed scrutiny assessment.
142(1)	Inquiry Notice	Request for additional documents, accounts, or information during an assessment.
156	Demand Notice	Issued when tax, interest, or penalty is payable.