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Business Audit Defense

Corporate Scrutiny, Transfer Pricing, CIT(A) Appeals & ITAT Representation

Protect your company from income tax demands. Expert defense for corporate scrutiny assessments, TP adjustments, reopening notices, and appeals at every level.

Corporate Tax Defense โ€” At a Glance

From scrutiny to appeal โ€” complete litigation support for businesses

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Scrutiny Assessment (143(2))

Under Section 143(2), the Assessing Officer (AO) selects returns for detailed scrutiny. You must respond within 30 days. We prepare point-by-point responses with financial statements, ledgers, and supporting documentation โ€” all submitted via e-proceedings on the Income Tax portal

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Transfer Pricing (Section 92+)

Companies with international transactions or specified domestic transactions above โ‚น20 crores must maintain Transfer Pricing documentation and file Form 3CEB (CA certificate). We handle TP study, ALP (Arm's Length Price) determination, Form 3CEB, and defend TP adjustments before the TPO (Transfer Pricing Officer)

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CIT(A) & ITAT Appeals

If the AO's assessment order is unfavourable, appeal lies before CIT(A) within 30 days of service of assessment order. If CIT(A) order is still unfavourable, second appeal before ITAT. We prepare detailed Grounds of Appeal, Paper Book, written submissions, and represent at all levels

Our Corporate Defense Services

Comprehensive legal defense at every stage of the tax dispute lifecycle

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Corporate Scrutiny โ€” Section 143(2)

AO issues notice under Section 143(2) within 6 months of filing if return is selected for scrutiny. Notice specifies documents required. We prepare complete response: financial statements, tax audit report Form 3CD, depreciation schedule, loan ledgers, investment details, advances explanation. All submissions via ITBA/e-proceedings portal. Response strategy to avoid additions to income

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Transfer Pricing Defense

Section 92 requires international transactions at Arm's Length Price. TP methods: CUP, RPM, CPM, TNMM, PSM. Form 3CEB (Accountant's Certificate) filed along with ITR. TPO issues notice under Section 92CA for examination. TP documentation maintained per Rule 10D. We prepare TP study report, defend comparables selection, and handle DRP/ITAT if TP adjustment proposed

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Reopening Defense โ€” Section 147/148

AO can reopen assessment if income has "escaped assessment" โ€” up to 3 years (reduced from 6 years from AY 2022-23), and 10 years for international transactions/searches. Before sending notice under 148, AO must send Show Cause Notice under 148A. We file objections under 148A(b), challenge the legality of reopening, and defend the reopened assessment comprehensively

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First Appeal โ€” CIT(A)

Appeal before Commissioner of Income Tax (Appeals) must be filed within 30 days of service of assessment order along with Form 35. Stay of demand application filed simultaneously to avoid coercive recovery. We prepare detailed Grounds of Appeal, compile Paper Book, file written submissions, and appear before CIT(A) for hearings. Timeline: CIT(A) disposal target is 12 months

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Dispute Resolution Panel (DRP)

DRP is an alternative dispute resolution for: (1) Transfer pricing adjustments; (2) Foreign companies. DRP consists of 3 Principal Commissioners. Objections to draft order filed within 30 days under Section 144C. DRP issues binding directions to AO within 9 months. DRP proceedings are often faster than CIT(A) for TP disputes and involve simultaneous filing with ITAT

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ITAT โ€” Second Appeal

Income Tax Appellate Tribunal (ITAT) hears appeals against CIT(A) orders. Bench composition: one Judicial Member + one Accountant Member. Appeal filed within 60 days of CIT(A) order. We prepare detailed legal grounds, compile Paper Book with case laws and ITAT precedents, file written submissions, and make oral arguments. ITAT orders are final on facts; only legal questions go to High Court

Who We Serve

Corporate audit defense across all business types and industries

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Private Limited Companies

ITR-6 filers โ€” corporate scrutiny 143(2), MAT adjustments, depreciation disputes, disallowances under 14A and 43B, Section 269SS/T cash transaction notices

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LLPs & Partnership Firms

ITR-5 filers โ€” partner remuneration disallowance disputes (Section 40(b) limits), interest on capital, brought-forward losses, presumptive taxation transition notices

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Companies with Foreign Transactions

Transfer pricing notices, PE (Permanent Establishment) disputes, Section 195 non-resident TDS demands, FEMA compliance related income tax notices, Form 15CA/15CB issues

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Startups & Scale-ups

Section 56(2)(viib) angel tax notices (unlisted company shares at premium), ESOP valuation disputes, Section 68/69 unexplained cash credit/investment notices

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Real Estate & Construction

Section 43CA fair market value additions for property sold below stamp duty value, Section 269SS/269T cash payment notices, project-wise income recognition disputes

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Retail & E-Commerce

Section 194-O TDS on e-commerce, GST and income tax correlation disputes, inventory valuation notices, Section 44AA books of account requirements for businesses

Our Defense Process

Systematic tax dispute resolution in 4 stages

01

Notice Analysis & Strategy

We review the notice: type (143(1) intimation vs 143(2) scrutiny vs 147/148 reopening), issues raised, time limit for response, and the AO's likely concern. We draft a response strategy that directly addresses the issue with minimum disclosure โ€” preserving privilege on information not asked for

02

Documentation Assembly

Gather all evidence: audited financial statements, Form 3CD tax audit report, ledger extracts, bank statements, depreciation schedules, investment evidence, loan agreements, and any other documents relevant to the specific issues raised. We prepare an indexed Paper Book for systematic submission

03

Filing Response / Appeal

For assessment notices: submit via e-proceedings on Income Tax portal within deadline. For CIT(A) appeals: file Form 35 online with Statement of Facts, Grounds of Appeal, and Paper Book. For ITAT: file Form 36 with memo of appeal, grounds, and detailed written submissions. Stay of demand application filed simultaneously

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Representation & Follow-up

Attend hearings before AO, CIT(A), or ITAT as authorised representative. Present written submissions, answer AO queries, and make legal arguments. Monitor status on ITBA portal. Escalate to High Court under Section 260A for substantial questions of law if ITAT order is adverse

Documents to Share Immediately

Send these along with the notice for fastest response preparation

โœ“ Notice received (copy of entire notice with section cited)
โœ“ PAN and Tan of the company
โœ“ ITR-V and ITR computation for the assessment year under notice
โœ“ Audited financial statements (P&L, Balance Sheet)
โœ“ Form 3CD tax audit report
โœ“ Depreciation schedule (in case of depreciation disputes)
โœ“ Bank statements for the relevant assessment year
โœ“ Loan/advance agreements if loan-related issues raised
โœ“ Investment proof for Section 68/69 notices
โœ“ Previous year's assessment orders (if any)

Why Choose Us for Audit Defense

Strategic, evidence-backed defense that protects your interests

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Strict Timeline Management

143(2) notice: 30 days to respond. Section 148A(b): 15โ€“30 days. CIT(A) appeal: 30 days from assessment order. Stay application: within 30 days of demand. We monitor every deadline โ€” missing it forfeits rights and can lead to ex-parte assessments and demands becoming payable

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Legal Privilege Protection

We respond to only what is specifically asked. Volunteering additional information during assessments can trigger further scrutiny. Our approach: answer narrowly, provide only the documents requested, and avoid creating new issues

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Stay of Demand

An adverse assessment order can result in income tax demands. Under Section 220(6), stay of demand can be granted pending CIT(A) disposal on payment of 20% of disputed demand. We file stay applications immediately after unfavourable orders to prevent coercive recovery

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ITAT Case Law Research

ITAT and High Court precedents are critical โ€” an identical fact pattern decided in your favour by any ITAT bench across India is persuasive. Our team researches recent ITAT orders on identical issues before every appeal to strengthen your legal position

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Rectification under Section 154

Obvious errors in assessment orders โ€” wrong section cited, computational errors, income double-counted โ€” can be rectified by the AO under Section 154 within 4 years. Faster and simpler than filing an appeal. We identify all 154 rectification opportunities before recommending the appeal route

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Complete Representation Rights

Authorised representative (CA/Advocate) can appear on behalf of the company without the director needing to be present. We prepare Power of Attorney and Vakalatnama as required. All correspondence through us โ€” protecting management from undue stress during proceedings

Frequently Asked Questions

Common questions about corporate tax disputes in India

Received a Tax Notice? Act Immediately.

Every tax notice has a strict deadline. Missing the response window can lead to ex-parte assessments and large demands. Contact us within 24 hours of receiving any notice.

TaxGenius

Professional accounting services in Canada and the United States

Services

  • Tax Preparation
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