Our advocates and chartered accountants possess in-depth expertise in international tax matters, focusing on key aspects such as Double Taxation Avoidance Agreements (DTAAs), Permanent Establishments (PE), concepts of residence and source-based taxation, royalty and dividend taxation, and Most Favored Nation (MFN) clauses. Our adept team ensures our clients' tax structures are optimized for global operations, mitigating potential tax liabilities and risks while ensuring full compliance with international tax laws.
Treaty Benefits
Ensuring multinational and international clients avail treaty benefits as deserved, defending against allegations related to treaty abuse, treaty overrides, disqualifications from availing treaty benefits, residence challenges, institution of permanent establishments, passive income (royalty, dividend, interest, house property) attributions, besides others.
Permanent Establishments
Advising businesses having or seeking to have presence in multiple jurisdictions regarding permanent establishment (PE) rules as per tax treaties, profit attributions, functional distribution between constituent entities, and defending PE implications raised by tax departments.
Individual International Tax Issues
Advising individuals on issues arising in dependent (employee) personal services and independent (professional) personal services taxation across jurisdictions.
MLI and BEPS Compliances
Navigating clients through the global consensus regarding international tax evasion and anti-abuse rules, multi-lateral instrument (MLI) and Base Erosion and Profit Shifting related regulatory and statutory compliances.
Foreign Tax Credit
Advising on mitigating tax liabilities by availing foreign tax credits and underlying tax credits, advising on filing statutory returns and refund claims to rectify incorrect tax payments.
Integrating International Tax and Transfer Pricing
Offering comprehensive advice to multinational businesses, by integrating international tax law with transfer pricing strategies, ensuring a holistic approach to cross-border tax optimization.
Litigation
Representing client interests before the assessing and investigating authorities, Commissioner of Income Tax (Appeals), Income Tax Appellate Tribunal (ITAT), Authority for Advance Rulings, various High Courts and the Supreme Court of India.
More Insights
10-07-2026
7
min read
Faceless Reassessment after S. 147A: What the Supreme Court Did – and Did Not – Decide
The Supreme Court's decision in Tej Pratap Singh does not settle the JAO–FAO controversy. Following Parliament's retrospective insertion of s. 147A, it remands the issue to the High Courts for fresh consideration. Faceless reassessment was never merely about moving tax files from paper to portal; it fundamentally changed the statutory authority responsible for communicating with the taxpayer, examining the record, drafting the order and completing the assessment. The real question now is how far a retrospective legislative clarification can go.
2026-04-23
18
min read
Mandatory Pre-Deposit for Appeals in Indirect Tax Laws: A Barrier to Justice?
Mandatory pre-deposit has become a defining feature of indirect tax litigation, balancing revenue protection with access to appellate remedies. While the shift to a fixed statutory framework has improved procedural efficiency, it also raises concerns regarding financial barriers and effective access to justice. This insight examines the legal evolution, judicial interpretation, and practical implications of the regime.
2025-06-28
4
min read
Beyond Procedural Lapse: Delhi High Court Rules GST Proceedings Against Non-Existent Entity Void ab initio
The Delhi High Court in HCL Infosystems Ltd. v. Commissioner of State Tax reaffirmed that GST proceedings against a company dissolved due to amalgamation are void ab initio. The Court held that such actions are not curable under section 160 of the CGST Act, nor authorised by section 87. This judgment aligns with the Supreme Court’s ruling in Maruti Suzuki, reinforcing the principle that legal proceedings cannot be pursued against non-existent entities.