Our firm's expertise in transfer pricing helps businesses establish arm's length pricing and navigate transfer pricing regulations to avoid disputes and penalties, select the most appropriate method, and identifying comparables. We offer comprehensive support in compliance, documentation, and representation in transfer pricing law. Our advocates and chartered accountants possess in-depth expertise in the latest developments in the law and OECD forums and the international jurisprudence in transfer pricing.
Transfer Pricing Studies
Advising on and reviewing transfer pricing studies, justification and accuracy of comparables and the most appropriate method, review of functions, assets, and risk (FAR) analyses of businesses, to ensure an accurate compliance with the arm’s length principle.
Comparable Analysis and Defence
Advising and representing clients in challenges to the selections of comparables for deciding the arm’s length price, review of functional analysis, contractual terms, economic realities, and business strategies for defending transfer pricing comparables.
Intangibles and Intellectual Property
Navigating through the complexities of intangible assets (technology intangibles, trade intangibles, marketing intangibles etc.) and intellectual property (IP) in the realm of transfer pricing and justification of the arm’s length price of these properties.
Cost Sharing and Inter-company Services
Offering guidance on cost-sharing arrangements, ensuring compliance with regulatory requirements while optimizing the allocation of costs among group entities and pricing inter-company (intra-group) services.
Integrating Transfer Pricing and International Tax
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, Transfer Pricing Officers (TPO), Commissioner of Income Tax (Appeals), Dispute Resolution Panel (DRP), Income Tax Appellate Tribunal (ITAT), 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.