Direct Tax Litigation, Search Defense & Reassessment Advisory
Senior partner-led representation for corporate entities, promoters, and high-net-worth individuals in Section 132 search and seizure block proceedings, Section 148A reassessment defense, and appellate advocacy before CIT(A) and ITAT.
Section 132 Search & Seizure
Immediate on-site rights advisory, statement defense under Section 132(4), cash/jewelry release applications, and defending block assessment proceedings before the Investigation Wing.
Section 148A Reassessment Defense
Challenging time-barred reassessments beyond 3 years, invalidating notices with escaped income under ₹50 Lakhs (Section 149(1)(b)), and filing Section 148A(b) show-cause replies with jurisdictional defenses.
Appellate Advocacy: CIT(A) & ITAT
Preparation of comprehensive Grounds of Appeal, Statements of Facts, paper books, and verbal advocacy before the Commissioner of Income Tax (Appeals) and Income Tax Appellate Tribunal (ITAT).
Technical Defenses in Direct Tax Inquiries
1. Section 148A Jurisdictional & Procedural Flaws
Under the post-Finance Act 2021 reassessment regime, the Assessing Officer MUST provide the underlying inquiry material under Section 148A(b) and obtain approval from the specified higher supervisory authority under Section 151. Notices issued without providing complete reasons or approved by incorrect authorities are void ab initio.
2. Section 68 / 69 Unexplained Cash Credits & Capital Scrutiny
Protecting business promoter capital accounts, unsecured loans, and share application money by establishing the tripartite test: (1) Identity of creditor, (2) Creditworthiness of creditor, and (3) Genuineness of transaction through banking channels.
3. Section 2(22)(e) Deemed Dividend Mitigation
Structuring inter-company loans and advances between group entities and family members to defend against 35%+ punitive deemed dividend tax assessments by proving commercial expediency and ordinary course of business.
Confidential Tax Notice Evaluation
Senior litigation partners CA. Anil K. Sharma and CA. Pankaj Jain personally review assessment notices, summons, and appellate briefs under attorney-client confidentiality.