Litigation.
Representation in transfer-pricing and international-tax disputes, including APA and MAP.
About this service.
Multinational groups and cross-border investors facing transfer-pricing adjustments or international-tax disputes in India.
International-tax and transfer-pricing disputes arise on treaty interpretation, PE attribution and the arm's-length pricing of related-party transactions. Representation requires careful factual development and a well-documented technical position.
Dispute-resolution work includes Transfer Pricing Officer (TPO) audits, Dispute Resolution Panel (DRP) filings, and appeals before the Income-tax Appellate Tribunal.
The firm also advises and represents clients in Advance Pricing Agreement (APA) and Mutual Agreement Procedure (MAP) proceedings for the resolution of cross-border disputes.
What the engagement covers.
Transfer Pricing Officer (TPO) audit representation
Dispute Resolution Panel (DRP) filings
Appeals before the Income-tax Appellate Tribunal
Advance Pricing Agreement (APA) advisory and representation
Mutual Agreement Procedure (MAP) representation
Counsel briefing for High Court and Supreme Court matters
Applicable laws and standards.
Other tax services.
Top questions.
The questions clients most often ask about this service. For anything specific to your situation, write to the firm.
Transfer-pricing adjustments and international-tax disputes such as PE attribution and treaty interpretation.
An examination of related-party pricing by the Transfer Pricing Officer.
The Dispute Resolution Panel — an alternative to the first appeal for eligible assessees.
The Mutual Agreement Procedure — a treaty mechanism to resolve cross-border disputes between the two countries' authorities.
An Advance Pricing Agreement can pre-empt disputes by fixing the pricing methodology in advance.
Before the DRP or the Commissioner (Appeals), and the Income-tax Appellate Tribunal.
Yes. MAP and treaty relief can address economic double taxation arising from an adjustment.
Yes. TPO audits and appeals are handled under partner supervision.
They vary by forum; timelines are outside the firm's control.
Yes, for High Court and Supreme Court matters.
Looking for litigation support?
Write to the firm to discuss the engagement. Each engagement is scoped through a formal letter, preceded by independence and conflict-of-interest checks.