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
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
Transfer Pricing (Section 92+)
Companies with international transactions or specified domestic transactions above โน20 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)
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
Why Choose Us for Audit Defense
Strategic, evidence-backed defense that protects your interests
Strict Timeline Management
143(2) notice: 30 days to respond. Section 148A(b): 15โ30 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
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
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
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
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
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.
