30+ years of combined expertise in complex Indian taxation and compliance.
Discuss your unique tax situation with our senior partners. No obligation.
30+ years of combined expertise in complex Indian taxation and compliance.
Case Files • Tap to expand
Case ST/2024/TP-0847
Situation
Received TP adjustment notice of ₹85 Cr. Management fee lacked service-by-service benchmarking. R&D cost-sharing documentation inadequate for BEPS compliance. No Master File or CbCR filed, creating ₹50L+ penalty risk. Treaty benefits claimed without proper Form 10F documentation.
Intervention
Built detailed FAR analysis with transaction-by-transaction documentation
Prepared comprehensive benchmarking study using contemporaneous data
Created Master File, Local File, and CbCR for full BEPS compliance
Filed Form 10F and obtained TRC for all treaty transactions
Applied for Advance Pricing Agreement for 5-year certainty
Outcome
₹77 Cr
Adjustment Reduced
₹23 Cr
Tax Saved
5 Years
APA Certainty
100%
Penalty Avoided
Verified
K. Sami, Senior Partner
March 2024
Case ST/2024/CR-1203
Situation
Indian subsidiary facing transfer pricing adjustment and withholding tax liability on inter-company services. Significant exposure to penalties with effective tax rate at 38% due to suboptimal structure and missed treaty opportunities.
Intervention
Restructured service agreements with documented arm's length pricing
Obtained advance ruling on withholding tax exemption
Implemented tax treaty benefits under India-Singapore DTAA
Established comprehensive transfer pricing documentation framework
Created compliance calendar and real-time monitoring system
Outcome
₹4.2 Cr
Annual Savings
18%
ETR Reduction
100%
Penalty Avoided
5 Years
APA Obtained
Verified
K. Sami, Senior Partner
February 2024
Case ST/2024/MF-0456
Situation
₹1.8 Cr payable to MSMEs beyond 45 days creating 43B(h) exposure. Partners paying 42% marginal rate on pass-through profits. ₹3 Cr machinery misclassified at 15% depreciation instead of applicable 40% rate.
Intervention
Emergency prioritization of MSME payments before financial year-end
Complete asset register review and depreciation reclassification
Partnership to LLP conversion with optimized salary + profit structure
Implemented vendor MSME tracking system with automated 45-day alerts
Established annual documentation review process
Outcome
₹54L
Disallowance Prevented
₹75L
Extra Depreciation
12%
ETR Reduction
₹1.4 Cr
Year 1 Savings
Verified
K. Sami, Senior Partner
March 2024
Case ST/2024/IT-0789
Situation
POEM risk with all directors based in India and board meetings conducted locally. Treaty benefits claimed without Form 10F compliance. Withholding at maximum 20% rate on technical services with potential global income taxation exposure.
Intervention
Restructured board with independent Singapore-resident directors
Documented decision-making locations and governance processes
Filed Form 10F and obtained TRC for full treaty compliance
Implemented GAAR-proof operational substance requirements
Created board meeting and governance compliance calendar
Outcome
₹8.5 Cr
Treaty Benefits
50%
WHT Reduction
Zero
POEM Exposure
₹3.2 Cr
Annual Savings
Verified
K. Sami, Senior Partner
January 2024
Strict Confidence Protocol
Client identities have been anonymized to protect confidentiality. All figures represent actual documented outcomes. Past results do not guarantee future performance and are contingent on the specific facts and circumstances of each matter.