Yes. Indian tax law requires taxpayers to obtain the mandatory registration for compliance with the tax law. However, there is no single registration covering all taxes; corporate income tax, GST and international trade are administered under separate statutory framework.

For corporate income tax purposes, the Permanent Account Number (PAN) issued by the Income Tax Department is the principal tax identification number. A company incorporated or taxable in India, is required to obtain a PAN, which is also widely used for banking, financial, commercial and other regulatory transactions.

For Goods and Services Tax (GST), a taxable person is required to obtain GST registration where the statutory conditions for registration are satisfied, including the applicable turnover thresholds and specified compulsory registration circumstances. Upon registration, the taxpayer is allotted a Goods and Services Tax identification Number (GSTIN). The GSTIN is PAN-based, and the registration is conducted electronically through the GST portal.

Import and export transactions are separately regulated. Customs authorities administer customs duties and border-related customs controls, while the Directorate General of Foreign Trade (DGFT) administers India’s foreign trade policy. An Importer Exporter Code (IEC) is generally required for undertaking import or export transactions and is linked to the taxpayer’s PAN, subject to applicable exemptions.

India primarily follows a self-assessment system under which the taxpayer is responsible for determining its taxable income or value of supply of goods or services, tax liability on the income or value of supplies and the amount payable in accordance with the applicable tax law.

In the context of income tax/ corporate tax, the taxpayer computes its taxable income after considering the applicable income, deductions, exemptions and tax rates and files the prescribed return of income. The return may be processed and accepted as filed; however, the tax authorities have statutory powers to select the returns based on internal parameters for scrutiny and undertake a more detailed assessment. In such cases, the taxpayer may be required to furnish information, documents and explanations supporting the disclosures made in the return. Based on the material available, the tax authority may accept the taxpayer’s position or make appropriate adjustments in accordance with the applicable provisions.

Where assessment results in an adjustment to the income or tax liability reported by the taxpayer, the taxpayer is generally provided an opportunity to respond to the proposed adjustment and has a statutory right of appeal against an adverse assessment order.

The GST regime also operates substantially on the principal of self-assessment. Taxpayers report their outward supplies, output tax liability and eligible input tax credit through the prescribed GST returns and are responsible for discharging the corresponding tax liability. Filing of GST return does not ordinarily result in a formal assessment order being issued by the tax authorities.

However, the absence of a formal assessment at the time of filing does not prevent subsequent verification. GST authorities may scrutinise returns, conduct departmental audits or investigations and seek information and supporting records from the taxpayers. Where discrepancies, short payment of tax, wrongful availment of input tax credit or other non-compliance are identified, the authorities may initiate proceedings and issue the appropriate statutory notice.

Accordingly, both income tax and GST are fundamentally self-assessment-based systems with the tax administration retaining powers of scrutiny, assessment, audit and investigation to verify the correctness of the taxpayer’s disclosure and determine any additional liability where warranted.

Yes. The ability to amend filed return differs materially between income tax and GST and is subject to the specific statutory mechanisms and time limits prescribed under each regime.

Under the income-tax law, a taxpayer may furnish a revised return where it discovers an omission or an incorrect statement in the original return, subject to applicable statutory conditions and prescribed time limit. As reflected in the current framework, under Section 263(5) of the Income Tax Act, 2025, a revised return may be furnished within nine months from the end of the relevant tax year or before completion of the assessment, whichever is earlier. The revised return mechanism therefore provides taxpayers with an opportunity to correct bonafide errors or omissions identified after the original return has been filed.

The position under GST is different. A GST return once filed cannot generally be revised as a whole. Instead, the GST framework permits correction or amendment of specified particulars through subsequent returns, subject to the prescribed conditions and statutory cut-off dates. Limited amendments to tax-invoice particulars have also been permitted through the GST return mechanism.

The principal mechanism through which the Indian tax authorities challenge a taxpayer’s self-assessment is scrutiny, verification or audit followed by a statutory notice requiring the taxpayer to furnish information, documents, explanations and supporting records in relation to the tax position reported.

In the income-tax context, the tax authorities may scrutinise the return and seek clarification or supporting evidence in respect of particular disclosures, deductions, exemptions, transactions or other aspects of the computation. Where the taxpayer’s response does not substantiate the position adopted, the assessing authority may make appropriate adjustments and determine the resulting tax liability in accordance with applicable provisions.

Tax authorities may also initiate proceedings where information received from third parties, financial institutions, other government agencies, data analytics, intelligence inputs or other sources indicates that income or transactions have not been correctly reported. Such information may lead to further inquiry, reassessment or other statutory proceedings, depending on the circumstances.

Under GST, similar procedure is adopted through scrutiny of returns, departmental audit, investigation or verification of transactions. The authorities may examine issues such as outward supplies, input tax credit, valuation, classification and related-party transactions and, where discrepancies are identified, initiate proceedings for recovery of the alleged tax shortfall, together with applicable interest and penalty.

The time limit for challenging a taxpayer’s self-assessment is prescribed separately under the relevant tax legislation and depend upon the nature of the proceedings and the tax period involved. The limitation provisions are therefore an important statutory safeguard against reopening matters indefinitely.

Under the Income Tax Act, 2025, the reassessment framework for income that has escaped assessment is contained in Sections 279 to 286 and applies to tax years commencing on or after 1 April 2026. For earlier tax years, the reassessment provisions of the Income-tax Act, 1961 continue to apply.

Under Section 282 of the Income-tax Act, 2025, a notice for reassessment under Section 280 generally cannot be issued after four years and three months from the end of the relevant tax year. This period may extend to six years and three months where the Assessing Officer is in possession of books of account, documents or other evidence relating to an asset, expenditure, transaction or entry indicating that escaped income amounts to, or is likely to amount to, INR 50 lakh or more. A corresponding limitation framework applies to the preliminary show-cause notice under Section 281.

For GST, the limitation period depends upon the statutory provision under which the tax demand is proposed and the nature of the alleged non-compliance. Accordingly, rather than applying a uniform period to every GST challenge, the relevant demand provision, tax period and applicable circumstances must be examined. In case the proposed tax recovery is not on account of serious offences such as fraud or evasion of tax, the limitation period is taken as 33 months from the date of filing of annual return. However, in situation where serious offences are alleged, the limitation period is taken as 54 months from the date of filing of annual return. It is to be noted that these stated limitation periods are appliable till Financial Year 2023-24. From Financial Year 2024-25, the above distinction has been removed, and a uniform limitation period now operates, which is, 42-month period from filing of the annual return.

‘Fraud’ in tax generally refers to the deliberate and illegal tax reduction method. The Indian Income Tax Law does not contain a definition of ‘fraud’. Thus, general meaning of ‘fraud’ is adopted authorities and taxpayers.

Even the Indian GST Law, does not define ‘fraud’ but it defines the term ‘suppression’, which is relevant for invoking penal consequences. The term ‘suppression’ has been defined under the Indian GST Law, as non-declaration of facts or information which a taxable person is required to declare in the return, statement, report or any other document furnished under this Act, or the rules made thereunder, or failure to furnish any information on being asked for, in writing, by the proper officer. The term fraud is much more narrowly interpreted by the Courts and deliberate action to evade taxes is required. As per judicial precedents, the fraud arises out of deliberate active role of representator about a fact which he knows to be untrue, yet he succeeds in misleading the representee by making him believe it to be true. The representation to become fraudulent must be of the fact with knowledge that it was false.

Tax fraud and deliberate tax evasion are treated as serious offence under Indian tax law and may give rise to both civil and criminal consequences, depending on the nature and severity of the conduct.

At the civil level, a taxpayer found to have deliberately concealed income, furnished inaccurate particulars, or otherwise engaged in fraud, wilful misstatement or suppression may be liable for recovery of the tax shortfall, applicable interest and substantial penalties. The quantum of penalty depends upon the specific statutory provision invoked and the nature of the contravention; in serious cases, the penalty may be linked to a significant percentage of the tax sought to be evaded.

In appropriate cases, tax authorities may also undertake investigation and prosecution proceedings where the conduct satisfies the statutory requirements for a criminal offence. Criminal liability is not automatic merely because an assessment results in additional tax; the prosecution must be founded on the ingredients of the relevant offence and the applicable procedural requirements.

Criminal offences under Indian tax legislation may carry imprisonment together with a fine, with the applicable sentence varying according to the nature and gravity of the offence. Accordingly, tax fraud can expose a taxpayer not merely to additional tax and penalties but, in appropriate cases, to criminal prosecution and custodial consequences.

The distinction between an inadvertent tax error and deliberate fraud is therefore important: criminal prosecution is ordinarily concerned with conduct satisfying the specific statutory elements of an offence, rather than with every instance of an incorrect tax position.

Yes. Although the Indian income-tax framework does not prescribe a general departmental audit of every taxpayer, the administration of assessments and tax proceedings is guided by instructions, orders and circulars issued by the Central Board of Direct Taxes (CBDT). These administrative directions are intended to promote consistency and uniformity in the manner in which income-tax authorities undertake assessments and exercise their statutory powers.

The CBDT, as the apex administrative body for direct taxes, periodically issues instructions, orders and circulars dealing with assessment procedures, scrutiny parameters and administrative practices. These directions provide guidance to tax officers and, where applicable, clarify procedural requirements for taxpayers. Their purpose is to ensure greater consistency in tax administration and to facilitate the proper implementation of the statutory framework.

In the GST context, the Central Board of Indirect Taxes and Customs (CBIC) has issued the Model All India GST Audit Manual, 2023, which provides a structured framework and guidance for departmental audits. The Manual sets out standards and procedures intended to promote a more consistent approach to the conduct of GST audits across jurisdictions.

Accordingly, while the detailed audit framework differs between income tax and GST, taxpayers are not operating in an entirely unstructured environment. CBDT instructions and circulars and the CBIC’s GST audit guidance provide administrative standards for tax officers, while the underlying statutory provisions and principles of natural justice continue to govern the exercise of audit and assessment powers.

Yes. Indian tax authorities have statutory powers to compel taxpayers and, in appropriate circumstances, third parties to furnish information, documents, data and explanations relevant to tax proceedings. These powers may be exercised during assessment, audit, investigation or other proceedings, subject to the requirements of the applicable tax legislation.

Information may be sought through written notices, electronic communications and the relevant tax portals. Depending on the nature of the proceedings and the statutory powers being exercised, the information sought may include accounting records, transaction details, supporting documentation and relevant electronic records. The source material specifically recognises that information may be sought through emails or tax portals.

The tax authorities may also seek information from third parties having commercial or financial dealings with the taxpayer. In addition, the authorities have powers to issue summons to officers, employees or other persons connected with the taxpayer for obtaining information relevant to tax proceedings.

Ordinarily, a taxpayer does not have a statutory right of appeal against a mere requisition for information, as such a requisition is generally an interlocutory procedural step rather than a final determination of tax liability. However, in appropriate circumstances, a taxpayer may invoke the writ jurisdiction of the jurisdictional High Court, particularly where the notice or requisition is alleged to be without jurisdiction, arbitrary, procedurally defective or otherwise contrary to law.

Accordingly, while the tax authorities have extensive information-gathering powers, these powers remain subject to the statutory framework and judicial review, particularly where there is a challenge to the jurisdiction or legality of the information request.

Yes. Indian tax authorities have statutory powers to compel third parties to furnish information, documents and records that are relevant to a tax enquiry, assessment, audit or investigation concerning a taxpayer. Such powers enable the tax administration to independently verify information reported by the taxpayer and obtain evidence from persons having knowledge of, or commercial dealings with, the relevant transactions.

The information sought may include transaction records, books and documents, confirmations and other information relevant to determining the taxpayer’s tax liability. A third party receiving a valid statutory requisition is generally required to comply with the request, and failure to furnish the information or documents may attract the penal consequences prescribed under the applicable tax legislation.

Ordinarily, a third party does not have a statutory right of appeal against a mere information requisition, since such a notice is generally procedural in nature and does not itself determine any tax liability. However, where the third party believes that the notice is without jurisdiction, legally defective, arbitrary or otherwise contrary to law, it may, in appropriate circumstances, invoke the extraordinary writ jurisdiction of the jurisdictional High Court.

Thus, while the tax authorities possess broad third-party information-gathering powers, those powers remain subject to the statutory limits governing the relevant proceeding and judicial review by the High Court in appropriate cases.

India does not generally provide a broad, negotiated settlement mechanism under which a taxpayer and the tax authority can enter into a binding agreement to conclusively settle an ongoing tax audit or assessment without recourse to the statutory adjudication and appellate process.

However, the Government has, from time to time, introduced specific statutory dispute-resolution or settlement schemes to facilitate the resolution of pending tax disputes. Such schemes may permit eligible taxpayers to settle specified disputes on prescribed terms, including payment of a determined or specified portion of the disputed tax, with consequential withdrawal or closure of the covered litigation.

These schemes are exceptional and scheme-specific, rather than forming part of the ordinary assessment process. Their availability, eligibility conditions, settlement amount and consequences depend upon the particular legislation or scheme in force at the relevant time.

Accordingly, while a taxpayer generally cannot negotiate a binding settlement of an audit with the tax authority as a matter of course, statutory dispute-resolution schemes may provide an opportunity to resolve eligible tax disputes without pursuing prolonged litigation.

India does not currently have a separate, specialised statutory grievance-redressal mechanism exclusively addressing the manner or pace of an ongoing tax audit or assessment. However, taxpayers are not without remedies where they have concerns regarding the conduct of tax proceedings.

As an initial administrative measure, a taxpayer may raise its grievance before the concerned supervisory or senior tax authority, particularly where the concern relates to procedural delays, unreasonable information requests or the manner in which the proceedings are being administered. The taxpayer may also use the applicable administrative grievance mechanisms, where available.

Where the conduct of the tax authorities is alleged to be arbitrary, without jurisdiction, procedurally unfair or otherwise contrary to law, the taxpayer may invoke the extraordinary writ jurisdiction of the jurisdictional High Court under Article 226 of the Constitution of India. Depending on the circumstances, the High Court may issue appropriate directions or relief to ensure that the tax authorities exercise their statutory powers in accordance with law.

The writ remedy is, however, discretionary and is not ordinarily intended to replace the statutory appellate mechanism where an effective alternative remedy is available. It is particularly relevant where the grievance concerns the legality or jurisdiction of the proceedings, breach of natural justice, or manifestly arbitrary exercise of statutory power. Accordingly, a taxpayer’s remedies may operate at two levels: administrative escalation within the tax department and, in appropriate cases, judicial review by the jurisdictional High Court.

Yes. A taxpayer who is aggrieved by an assessment order or other appealable order passed by the tax authorities generally has a statutory right of appeal before the appropriate appellate forum, subject to the requirements and limitations prescribed under the relevant tax legislation.

The first appeal is ordinarily filed before the designated first appellate authority, which may examine both the factual and legal aspects of the assessment, subject to the scope of its statutory powers. Depending upon the outcome and the applicable legislation, the taxpayer may have further rights of appeal before the tax tribunal, High Court and ultimately the Supreme Court.

The right of appeal is, however, subject to strict statutory time limits and procedural requirements. The taxpayer must therefore ensure that the appeal is filed within the prescribed limitation period and in the prescribed form, together with any applicable filing requirements.

Where the taxpayer is unable to file an appeal within the prescribed period, the relevant appellate authority may, where the statute permits and sufficient cause is demonstrated, have power to condone the delay.

Accordingly, the Indian tax dispute framework provides taxpayers with a structured appellate remedy against adverse assessments, while requiring timely compliance with the applicable limitation and procedural requirements.

In India, the appellate route consists of quasi-judicial and judicial bodies. Typically, after the assessment, the tax disputes are raised before the appellate authority, which acts as both fact-finding authority and adjudicator. The powers of the first appellate body are co-extensive and coterminous to the primary tax authority. The second appellate body is the tax tribunals, where the appeal is heard in a manner like that of a civil court. The Tribunal typically consists of two members i.e. one judicial member and another member representing the revenue department. Accordingly, both these bodies are quasi-judicial in nature.

The next two appellate foras are the High Court and the Supreme Court, which are judicial forums.

Proceedings before the tax tribunals, High Courts and the Supreme Court of India are generally conducted in public, subject to applicable procedural rules and any specific directions of the concerned forum. Orders and judgments delivered by these judicial and quasi-judicial forums are generally available in the public domain.

Basic information concerning tax appeals including case numbers, parties, orders, proceedings and judgments may generally be accessed through the official websites of the respective courts and tribunals, as well as established legal databases.

However, public access is not unlimited. Taxpayer-specific records, confidential documents, detailed case materials and other non-public information may not be available to third parties merely because a dispute is pending before a judicial forum. Access to the underlying tax records will depend upon the nature of the material and the applicable procedural and confidentiality requirements.

Accordingly, while tax litigation before the higher appellate forums is characterised by a significant degree of judicial transparency, the public does not necessarily have unrestricted access to the complete underlying record of a tax dispute. The distinction is particularly important between published judicial orders and judgments, which are generally accessible, and confidential taxpayer records and detailed case materials, access to which may be restricted.

The tax dispute resolution process in India generally involves a combination of written and oral procedures, although the relative importance of each may vary depending on the forum and stage of the proceedings.

Taxpayers and the tax authorities ordinarily place their respective cases on record through written submissions, replies, petitions, affidavits, documentary evidence and written arguments setting out the relevant factual and legal contentions. The written record is particularly important in establishing the factual foundation of the dispute and preserving the parties’ respective positions for appellate review.

This is complemented by oral hearings and arguments before the relevant tax authorities, appellate forums, tribunals and courts. During the hearing, the parties may clarify the factual record, address questions raised by the adjudicating authority or court and develop their legal submissions.

At the higher appellate levels, particularly before the High Courts and Supreme Court, written pleadings and submissions form an important part of the record, while oral arguments are used to address the questions of law and other issues arising for determination.

Accordingly, Indian tax litigation is neither exclusively written nor exclusively oral. It follows a hybrid model in which comprehensive written submissions establish the case, supplemented by oral advocacy at the hearing stage. This approach is consistent with the general position reflected in the source document.

From a tax perspective, India does not generally have a formal, court-administered document discovery process comparable to the discovery procedures found in certain common-law jurisdictions. Instead, documents and evidence are ordinarily gathered during the assessment, audit or investigation stage, either through the taxpayer’s submissions or pursuant to information requests issued by the tax authorities.

The tax authorities may require the taxpayer to furnish books of account, agreements, invoices, correspondence, transaction records and other documents relevant to the proceedings. Where a tax authority proposes to rely upon particular documents or material against the taxpayer, the principles of natural justice generally require that the taxpayer be given access to the material relied upon, subject to applicable statutory restrictions and claims of confidentiality. The source material similarly notes that the tax authorities are expected to provide the documents relied upon when issuing a tax notice.

The process is therefore principally investigation and disclosure-driven rather than discovery-driven. There is no general procedure under which the taxpayer and the tax authority are required to undertake reciprocal discovery of all documents potentially relevant to the dispute.

Further, the ability to introduce additional documents after a notice or at the appellate stage may be subject to the applicable procedural rules and the discretion of the relevant authority or appellate forum. Accordingly, taxpayers should ensure that all material evidence supporting their position is properly documented and placed on record at the appropriate stage.

In practice, contemporaneous documentation and preservation of the underlying transaction record are particularly important, as the absence of a formal discovery process places greater emphasis on the documents produced during assessment, audit or investigation.

Yes. Indian tax authorities have statutory powers to summon persons and obtain evidence or statements during the assessment, audit or investigation stage. Witness evidence may therefore form part of the evidentiary record in tax proceedings, particularly where the authorities are investigating the underlying facts or transactions.

The use of witness evidence is, however, more commonly associated with the assessment and investigation stages, where the tax authorities may require a person connected with the taxpayer or the relevant transaction to provide information or give a statement. The source material indicates that the process of obtaining such evidence is generally undertaken before the issuance of the tax notice.

Once formal tax proceedings have commenced, the evidentiary process is primarily conducted through the documents and material placed on record, together with the taxpayer’s written responses and submissions. The extent to which further oral evidence may be introduced thereafter depends on the applicable statutory procedure and the powers of the relevant adjudicating or appellate forum.

Witnesses may also be examined in criminal proceedings arising from serious tax-evasion allegations, where the ordinary rules and procedures governing criminal trials apply.

Accordingly, while witness evidence is available under Indian tax law, tax disputes are predominantly document-driven, with witness statements and oral testimony playing a more significant role at the investigation stage and, where applicable, in subsequent criminal proceedings.

In India, the court proceedings operate on the principle that the initial burden of proof rests with the party who has appealed the case to court. This means that the appellant carries the initial burden in tax cases. If the tax department is the appellant, it must prove that the taxpayer has evaded income. Conversely, if the taxpayer is the appellant, the burden is on them to disprove the issues raised in the assessment that is the subject of the appeal.

In India the time taken for an appeal to conclude depends on mainly the issue involved in the appeal as well as the forum at which the dispute is pending. In scenarios where the issue involved in tax appeal has already been decided by Courts, in practice it may take upto 2-3 years for the tax case to conclude.

However, if the tax appeal involves a substantial issue affecting an industry, it may take upto 5-7 years to resolve since in practice, the appeal travel till the Supreme Court of India for a resolution.

Yes, a taxpayer is typically required to pay upto 20% of the disputed tax amount while preferring an appeal upto tax tribunal. This is termed as ‘pre-deposit’ and is compulsorily required to be discharge while exercising the right to appeal.

With respect to appeals to High Court and Supreme Court, there is no law-prescribed pre-deposit to be discharged. Ordinarily, the taxpayer must obtain a judicial order from High Court or Supreme Court for staying the recovery of tax amount. In case, the Stay Order is not granted then the entire differential tax amount may be recovered by the tax authorities.

Every taxpayer is entitled to representation either by itself or through an authorised representative. A taxpayer may represent himself with proper written authorisation by a Chartered Accountant or an Attorney before any quasi-judicial authorities i.e. until the tax tribunal stage. However, only an Attorney can represent a taxpayer before the High Courts and Supreme Court of India.

No, India has no current mechanism wherein the ‘loser pays’ the winner’s legal/professional costs of an appeal.

In general, Indian tax law does not provide for voluntary mediation or binding private arbitration as an alternative to the statutory tax assessment and appellate process. Tax liability is ultimately determined under the relevant tax legislation, and a taxpayer and the tax authority cannot ordinarily contractually determine or compromise the tax liability through private dispute-resolution mechanisms.

An important exception in the context of international taxation is the Mutual Agreement Procedure (MAP) available under applicable Double Taxation Avoidance Agreements (DTAAs). MAP may be invoked where a taxpayer considers that the actions of one or both treaty jurisdictions result, or are likely to result, in taxation that is not in accordance with the applicable DTAA. The competent authorities of the relevant jurisdictions then engage in discussions with a view to resolving the issue and, where appropriate, eliminating or reducing double taxation. MAP is therefore a government-to-government treaty mechanism, rather than mediation or arbitration between the taxpayer and the tax authority.

MAP is subject to the terms of the applicable DTAA and the relevant domestic procedure, including any prescribed time limits and procedural requirements. It is particularly relevant for cross-border disputes involving issues such as transfer pricing adjustments, permanent establishment, characterisation of income and allocation of taxing rights.

Separately, Advance Ruling provides an ex-ante certainty mechanism in specified circumstances. An eligible taxpayer may approach the competent Advance Ruling Authority in respect of a specified transaction or proposed transaction to obtain a determination on its tax treatment. The ruling is intended to provide certainty to the taxpayer and the tax administration, subject to the statutory conditions governing its applicability and binding effect.

Accordingly, while mediation and private arbitration are generally unavailable for resolving Indian tax liability, MAP provides a significant treaty-based dispute-resolution mechanism for eligible international tax disputes, while Advance Ruling operates as a pre-transaction certainty mechanism rather than a substitute for ordinary tax litigation.

Yes. Indian tax law generally provides for a structured hierarchy of appellate remedies, although the precise appellate route may vary depending upon the nature of the tax dispute and the governing legislation.
Broadly, an appeal may proceed from the initial assessment or adjudication authority to the designated first appellate authority. From there, an eligible dispute may proceed to the relevant tax tribunal, which generally functions as the principal fact-finding appellate forum.

Thereafter, where the statutory conditions are satisfied, an appeal may lie to the jurisdictional High Court, generally in relation to substantial questions of law or other questions permitted under the relevant legislation. The matter may ultimately reach the Supreme Court of India, which is the highest appellate court.

Tax penalty could range from 10% of the additional tax discharged to 100% of the additional tax discharge. The quantum of penalty is dependent on nature of allegation made against the taxpayer and evidence adduced to deflect the allegations. Further, there are situations which invite imposition of fixed amount as penalty, applicable to both the tax law i.e. income tax and Goods & Services tax.

To effectively mitigate imposition of penalties, a taxpayer is required to substantiate its bonafide to the tax authorities/ courts. The conduct of the taxpayer during assessment, records maintained, and disclosure made in the tax returns and financials are considered by authorities/ courts to reduce penalties.

In corporate income tax, the Indian Tax Authorities are likely to bring challenges on tax deduction claims, application of DTAAs & Transfer Pricing.

On the Indian GST Law front, tax authorities are likely to challenge availability of tax credits, Related Party Transactions and classification of goods and rate of GST. Further, from the Customs Law perspective, there could be possibility that authorities would challenge valuation of goods imported, Related Party Transaction and classification of goods.

Amidst the frequently changing tax laws in India and evolving jurisprudence from the Indian Courts, taxpayers often face challenges on tax administration front which covers multiple compliances and tax investigations. In recent times, intra-group services remain a very litigative issue both under Corporate Taxation as well as GST, wherein the issue ranges from transfer pricing and valuation of related party supplies. Further, tax treaty entitlement also remains a disputed area.