Tax Representation & Litigation Support Services
In the rapidly evolving Indian tax landscape, businesses and individuals increasingly face scrutiny and litigation from tax authorities. At Pratapkaran Paul & co, Chartered Accountants, we offer comprehensive tax litigation representation services in India, supporting clients through each phase of tax disputes—from routine investigations to high-stakes appellate hearings.
Our expert team specializes in tax representation before Assessing Officers, appellate representation before CIT(A), DRP, and ITAT, as well as High Court and Supreme Court representation through internal and external legal counsel. We also offer guidance on international tax disputes, transfer pricing litigation, and foreign asset investigations, ensuring robust support across complex cross-border tax matters.
Leveraging deep domain knowledge in both Indian and global tax regimes, we assist in strategic litigation planning, risk assessment, and proactive tax position sustainability analysis. Whether challenging a tax demand or seeking resolution of disputed tax positions, our services ensure you are well-prepared, represented, and supported at every stage.
Tax Representation During Investigations & Scrutiny
(Assessing Officer)
- We provide expert representation before the Assessing Officer and tax authorities during income tax scrutiny and investigation proceedings.
- We assist in preparing responses, collating necessary documents, and attending hearings to resolve issues efficiently.
- Our goal is to minimize demand and avoid penalties by addressing discrepancies and clarifying tax positions during the process.
- We liaise with revenue officers throughout the investigation, ensuring professional handling of notices and inquiries.
- Our representation enhances credibility and helps reduce disputes through detailed documentation and negotiation support.
Appellate Representation Services (CIT(A), DRP & ITAT)
- We provide professional appellate representation before the Commissioner of Income Tax (Appeals), Dispute Resolution Panel, and the Income Tax Appellate Tribunal.
- Our services include drafting comprehensive written submissions, filing appeals, and making oral arguments on behalf of clients.
- We present strong legal reasoning and evidence to challenge adverse orders and claims raised during appellate proceedings.
- We manage timelines and procedural compliance to ensure all submissions and hearings are handled seamlessly.
- Our appellate support helps clients recover or reduce contested tax liabilities and secure fair decisions.
High Court & Supreme Court Representation
- We offer strategic representation before the High Courts and Supreme Court via in-house tax litigation experts and external legal counsels.
- Our team assists in drafting curative petitions, special leave petitions, and legal briefs for high courts and SC cases.
- We handle complex tax matters involving constitutional issues, high-value disputes, or intricate transfer pricing cases.
- Our approach combines financial acumen with legal precision to present compelling arguments before the judiciary.
- Clients receive expert advice on escalation strategies and options for litigation resolution at the highest level.
International Tax & Transfer Pricing Dispute Resolution
- Our team navigates cross-border tax disputes involving transfer pricing adjustments, international taxation, and treaty-based issues.
- We handle documentation, policy support, and defense during audits or litigation involving related-party transactions.
- We advise on Double Taxation Avoidance Agreements (DTAA) and provide strategy to avoid or mitigate international tax exposure.
- Our services include defending related-party pricing adjustments before authorities and tribunals.
- We help multinational businesses maintain compliance and optimize tax positions across jurisdictions.
Strategic Litigation Advice, Risk Assessment & Ongoing Position Analysis
- We help clients develop strategic litigation plans, evaluate risks, and decide optimal resolution approaches.
- Our team reviews litigation history and tax positions periodically to ensure alignment with evolving precedents and regulations.
- We conduct tax position sustainability analysis, suggesting remedial actions where necessary.
- We assist in preparation and submission of advance ruling applications to the Authority for Advance Rulings (AAR).
- Our ongoing advisory supports businesses in staying ahead of potential tax disputes and reducing litigation exposure.
Representation Before CBDT for Exemptions, Condonation & Special Approvalss
At PKP & CO, we provide comprehensive support in securing statutory exemptions, condonation approvals, and special permissions from the Central Board of Direct Taxes (CBDT) under the Income-tax Act, 1961. These representations require a nuanced understanding of legal frameworks, precedents, and procedural compliance—areas in which we specialize.
We assist clients in drafting robust applications, preparing supporting documents, and making effective submissions to the CBDT for:
Statutory Exemptions (Section 10)
- Representation for obtaining tax exemptions under:
- Section 10(46): Income exemption for bodies/authorities notified by the Government
- Section 10(23C): Approval for charitable institutions and funds
- Section 10(23EC)/10(23ED): Income exemption for venture capital funds and trusts
- Section 10(24): Exemption for registered trade unions
- o Section 10(25): Exemption for provident or superannuation funds
- We assist in compiling documentation, financials, and legal rationale for qualifying under these sections
- Liaise directly with CBDT officers and submit follow-up queries or clarifications
Condonation of Delay Applications
- Filing and representation before CBDT for:
- Condonation of delay in filing Form 10B/10BB for charitable trusts
- Condonation of delay in filing Form 9A/10(application for accumulation)
- Late filing of Form 67 (foreign tax credit claims)
- o Condonation of late filing of returns under Section 119(2)(bfor genuine hardship cases
- Detailed drafting of condonation petitions highlighting reasonable cause and bona fide intention
- Continuous coordination with CBDT for expedited resolution
Approval for Income Tax Return Reprocessing & Refunds
- Representation for CBDT approval in:
- Reprocessing of ITR for refund beyond time-barred period
- Release of refunds held in abeyance due to legal/technical disputes
- Rectification under Section 154 that exceeds ordinary jurisdiction
- Submission of detailed representations citing CBDT Circulars, past rulings, and relief grounds
Special Permission Applications to CBDT
- We assist in drafting and filing applications seeking:
- Relaxation from TDS/TCS provisions under Section 197/206C(9)
- Exemptions or approvals under Section 80G or 35(1)(ii)for scientific research institutions
- Clarifications and relief through CBDT instructions and circulars
- Tracking of file movement and providing legal interpretations where required
- Continuous legal follow-up and expert representation until disposal of the matter
Our specialized team brings years of experience in handling complex submissions to CBDT, ensuring timely compliance, strong documentation, and maximum chances of favorable relief. From charitable institutions, non-profits, and government-backed authorities to corporates, we offer strategic advisory and end-to-end execution for clients needing special approvals or rectification.