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Services Offered For Businesses in India

Income Tax Lawyer Ahmedabad | Assessments, Reassessments & ITAT Appeals

Overview

Income tax law governs the levy, collection, and adjudication of direct taxes on individuals, corporates, and cross-border transactions. With constant legislative amendments, digitisation of proceedings, and a heightened focus on compliance, taxpayers today face a range of complex challenges — from faceless assessments and reassessment notices to TDS defaults, penalty exposure, and delayed refunds. At R&D Law Chambers, we focus on strategic representation and dispute resolution, rather than routine compliance or return filing. Our work spans assessments, reassessments, search and survey proceedings, penalty and prosecution defence, stay of demand, and multi-tier appeals before the CIT(A), ITAT, High Courts, and Supreme Court of India.
Contact Us
Our Ahmedabad base allows us to serve individuals, businesses, and multinationals locally, while also representing clients across India through faceless proceedings and appellate forums. While we do not claim to be the best income tax lawyers in Ahmedabad or one of the top income tax law firms in India, our commitment is to deliver clear, law-first solutions that align commercial objectives with statutory and judicial requirements. We believe that successful outcomes in tax litigation depend on a coherent factual record, rigorous legal interpretation, and timely procedural strategy. Our approach is designed to minimise risk exposure, secure relief (whether by stay, appeal, or writ), and protect the taxpayer’s right to fair treatment under the Income Tax Act.
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Key Services

Assessment & Reassessment Proceedings

We assist taxpayers in responding to notices under Section 142(1) (enquiry), 143(2) (scrutiny), and 143(3) (regular assessment), including faceless assessment submissions on the e-filing portal. Our work includes drafting replies, compiling supporting documentation, and addressing additions/disallowances. For reassessments under Section 147/148, we test the validity of reopening — limitation periods, tangible material requirements, and procedural compliance (GKN Driveshaft framework) — and raise objections before challenging unsustainable notices through writ petitions where necessary.

Search & Survey Defence

In search cases under Section 132 and survey proceedings under Section 133A, we advise on rights and obligations, preservation of evidence, and post-search strategy. While lawyers are not permitted to be present when statements are recorded, we review statements post-facto, advise on retraction or clarification, and prepare defence submissions for block assessment proceedings under Sections 153A/153C. We contest additions based solely on loose sheets or uncorroborated statements, invoke cross- examination rights, and align evidence to mitigate arbitrary assessments and penalties.

TDS / Withholding Tax Litigation

We advise and represent clients on domestic and cross-border withholding obligations, including Section 195 opinions, lower/nil deduction certificates, and disputes under Sections 201/206C. For corporates with global operations, we align TDS positions with DTAA benefits and ensure compliance with CBDT circulars to mitigate disallowances under Section 40(a)(i) or 40(a)(ia).

Advance Ruling & Tax Certainty

For cross-border transactions, we assist non-residents and Indian companies in seeking advance rulings on taxability of income, PE exposure, or withholding obligations under Section 245N and related provisions. Post transition to the Board for Advance Rulings (BAR), we prepare applications, compile supporting agreements, and make detailed written submissions to secure tax certainty before entering into high-value transactions. Where an unfavourable ruling is issued, we challenge it before the High Court under writ jurisdiction. We also handle Section 197 applications for lower/nil withholding certificates and Section 195(2) applications to determine appropriate TDS on cross-border remittances.

Penalty & Prosecution Defence

We handle challenges to penalties under Section 270A (under-reporting/misreporting), 271C (failure to deduct TDS) and similar provisions, ensuring that penalty initiation meets statutory preconditions. We also defend prosecution complaints under Sections 276C, 277 and assist in compounding applications or quashing petitions to safeguard clients from criminal exposure.

Appeals, Writs & High Court Representation

We prepare appeal memoranda before CIT(A) and ITAT, identifying strong legal grounds, evidentiary
gaps, and procedural lapses.

Our representation extends to High Courts, including the Gujarat High Court, and the Supreme
Court, where we:
File tax appeals under Section 260A on substantial questions of law.
Move writ petitions to challenge:
o Jurisdictional defects in reassessment notices.
o Mechanical orders under Section 220(6) refusing stay of demand.
o Special audit directions under Section 142(2A) passed without reasons.
o High-pitched assessments violating CBDT Instruction 1914 or natural justice
principles.
As Gujarat High Court lawyers handling tax litigation, we also seek interim relief —
stay on recovery, waiver of pre-deposit, mandamus for refund release, or quashing
of coercive action — ensuring taxpayers’ rights are protected at every stage.

Rectification &Revision

We file Section 154 applications to correct apparent errors in assessment orders and challenge adverse Section 263 revisionary orders before ITAT where conditions precedent are not satisfied. We also pursue Section 264 revision petitions to secure beneficial relief for taxpayers where appeals are not viable.

Refunds & Interest Claims

We represent clients in claiming interest under Section 244A for delayed refunds and contest unlawful adjustments under Section 245. Our approach combines representation before the Assessing Officer with writ petitions where refund release is unduly delayed.

Dispute Resolution Schemes

Where viable, we represent clients under government-led schemes such as Vivad se Vishwas or other settlement mechanisms, ensuring full and final closure of disputes in a cost-effective manner while safeguarding future tax positions.

Documents we Draft & Review

Our work involves preparing precise, authority-facing documents that withstand scrutiny at every stage of assessment and litigation. These include:
  • Assessment & Reassessment: Replies to Section 142(1), 143(2), 148 notices; objections to reopening under GKN Driveshaft framework; submissions for faceless assessments and penalty proceedings.
  • Search &; Survey Proceedings: Written submissions for block assessments (Sec 153A/153C); cross-examination requests; retraction affidavits and supporting legal representations.
  • TDS &; Withholding: Section 195(2) applications, lower/nil deduction applications under Section 197, and legal opinions on DTAA applicability.
  • Advance Ruling & Tax Certainty: Applications before the Board for Advance Rulings (BAR), including transaction briefs, question framing, and detailed supporting annexures.

Appeals & Writs:

  • CIT(A) & ITAT Appeals: Appeal memoranda, stay applications, additional evidence petitions.
  • High Court & Supreme Court: Tax appeals under Section 260A, writ petitions challenging reassessment notices, stay refusals, special audit orders, and refund delays.
  • Rectification &; Revision: Applications under Section 154, written submissions against Section 263 orders, and petitions under Section 264.
  • Refunds & Interest Claims: Representations for release of refunds, reconciliation statements, and interest computation claims under Section 244A.
  • Prosecution Defence: Replies to show-cause notices, compounding applications, and quashing petitions.
  • Dispute Resolution Schemes: Applications and declarations under Vivad se Vishwas or other government schemes, with computation of disputed tax and settlement amounts.

Our Approach

Intent-Led, Law-First trategy
Every tax dispute begins with understanding the commercial transaction or assessment trigger. We map it against the Income Tax Act, Rules, CBDT circulars, and judicial precedent, identifying lawful options and procedural timelines. We advise clients on whether to litigate, settle, or seek alternate remedies such as rectification or revision, ensuring that every step aligns with both the legal framework and the commercial goal.
Evidence-First Record
Curation When clients approach us, the record is often already shaped by filed returns, Form 26AS, books of account, agreements, and prior correspondence. Our role is to analyse the available material, identify gaps or inconsistencies, and decide what evidence should be produced, emphasised, or withheld to build the most defensible case. Where contradictions exist, we address them proactively — by providing context, additional documentation, or legal arguments — so that the overall narrative remains credible and supports the relief sought.
Authority-Facing Drafting
Our replies, objections, and appeal memoranda are drafted in the style expected by Assessing Officers, CIT(A), ITAT Members, and High Courts — clearly presenting facts, issues, and legal grounds with precise case-law support and computation summaries. We plan limitation, stay, and pre-deposit strategy from the outset to avoid procedural setbacks.
Parallel & Preventive Relief
We act early to avoid coercive recovery or procedural prejudice. Stay applications, writ petitions, and rectification requests are filed proactively where needed. For cross-border transactions, we promote advance rulings and lower withholding certificates to minimise future disputes and litigation exposure.
No Routine Compliance
We do not function as a return-filing or bookkeeping service. Our focus is purely on strategic, dispute-oriented representation — from defending reassessment notices to litigating before ITAT, High Courts, and the Supreme Court — so that every hour is invested in building a strong legal position.

Illustrative Scenarios

Faceless Scrutiny – Expense Proposal

A company’s return is selected for scrutiny under Section 143(2). During 143(3 assessment proceedings, the Assessing Officer proposes to disallow employee benefit expenses for lack of documentation. We can help by preparing a structured response with payroll records, board resolutions, and payment proofs, and by seeking Section 154 rectification where computational errors arise.

Reassessment Beyond Limitation

An individual receives a Section 148 notice more than four years after filing the return, despite full disclosure in the original return.

We can assist in preparing objections citing Section 149 time limits and leading case law, and if objections are dismissed, move a writ petition before the jurisdictional High Court to challenge the reopening.

Search Assessment – Loose Sheet Additions

Following a Section 132 search, additions are proposed solely on the basis of unsigned loose sheets found on the premises.

We can prepare defence submissions in block assessment proceedings under Section 153A, seek cross-examination of witnesses where statements are relied upon, and represent in ITAT if the dispute proceeds to appeal.

TDS Disallowance on Foreign Payments

A taxpayer faces disallowance under Section 40(a)(i) for not deducting tax at source on payments to a foreign service provider.

We can review the underlying agreements, examine DTAA provisions, and, where a Section 195(2) or 197 certificate exists, contest the disallowance before CIT(A) or ITAT to secure relief.

High Court Stay on Demand

A high-pitched demand is raised and a Section 220(6) stay application is mechanically rejected.
We can file a writ petition before the High Court, rely on CBDT Instruction 1914, and seek interim stay of recovery until appeal proceedings conclude.

Refund Delay & Interest Claim

Even after assessment is complete, a taxpayer’s refund remains unpaid.
We can represent before the Assessing Officer, file follow-up representations citing Section 244A, and where required, move a writ seeking mandamus for refund release with statutory interest.

Advance Ruling for Cross-Border Transaction

A foreign company planning to license intellectual property to its Indian affiliate wishes to confirm taxability and PE exposure in advance.

We can prepare and file an application before the Board for Advance Rulings, frame precise questions on royalty characterisation and withholding obligations, and represent through the ruling process.

Related Services

Income tax disputes often intersect with other practice areas. We frequently work alongside:

  • International Tax & Transfer Pricing – to align withholding tax positions, DTAA benefits, and TP adjustments with overall tax litigation strategy.
  • Corporate & M&A Advisory – to structure transactions and shareholder exits in a tax-efficient way, reducing future litigation exposure.
  • GST & Indirect Tax – to address parallel disputes on input credits, refunds, or tax treatment of cross-border transactions.
  • Dispute Resolution & Writ Practice – to plan appellate timelines, draft writ petitions, and escalate matters where natural justice is violated.

Frequently Asked Questions (FAQs)

Financing in India can take many forms, including bilateral loans, syndicated lending, project finance, acquisition finance, and securitisation. External Commercial Borrowings (ECBs) are also available to eligible Indian companies for raising funds from foreign lenders. Each structure has its own regulatory requirements under the Reserve Bank of India (RBI) and FEMA.
Initial Public Offerings (IPOs) in India are primarily governed by the Companies Act, 2013 and the SEBI (Issue of Capital and Disclosure Requirements) Regulations. Companies must undergo legal due diligence, prepare a prospectus, and obtain approvals from SEBI and stock exchanges. Compliance with disclosure norms and governance requirements is critical before shares can be offered to the public.
Banking disputes in India may arise under statutes such as the SARFAESI Act, before Debt Recovery Tribunals (DRTs), or in insolvency proceedings before the National Company Law Tribunal (NCLT). In Ahmedabad, NCLT benches frequently hear matters related to enforcement of security, restructuring, and insolvency. Arbitration may also be an option if provided for in financing agreements.
We analyse whether conditions for “under-reporting” or “misreporting” are actually met, and draft replies citing judicial precedents. In appropriate cases, penalties can be deleted at CIT(A) or ITAT stage.
An ITAT appeal must be filed within 60 days of receiving the CIT(A) order. We prepare grounds of appeal, compile evidence, and file stay applications where recovery is pending.
Yes. Section 244A provides for interest on delayed refunds. We prepare detailed computation and representation for release of both principal and interest, and file writ petitions if refunds are unduly withheld.
No. Our focus is on strategic, dispute-oriented representation — assessments, appeals, writs, and litigation strategy — not routine compliance or bookkeeping.

Office Details

To maintain transparency and consistency across all public listings, the exact details of our office are provided below. These are aligned with the firm’s Google Business Profile (GMB), ensuring accuracy for search visibility and authenticity.

 

R & D Law Chambers

604 Entice, Bopal-Ambli Road, Ahmedabad, Gujarat – 380058, India

Phone: 09898550411 | +91 9898550411

 

*This page is intended solely for informational purposes. It should not be construed as professional advice. The descriptions of practice areas and services are general in nature and are provided only to assist readers in understanding the range of corporate law and related legal issues commonly handled by corporate law firms in India.

Nothing on this page is to be taken as a guarantee of outcome or as an invitation to create a lawyer–client relationship. Readers are encouraged to seek independent professional advice based on their specific facts and requirements.

R & D Law Chambers makes every effort to ensure that the information presented is accurate as of the date of publication. However, laws and regulations evolve, and the applicability of legal principles may vary depending on the facts of each case. The firm disclaims any liability arising from reliance placed on the content of this page without obtaining tailored advice.

“In my experience in working with R & D Law Chambers, I have noted that they have never committed any unattainable outcomes; rather they have given a clear understanding about the possibilities. Favourable outcome is normally an automatic consequence of their best endeavours. Recently, with their assistance, Salus Product has been successful in recovery of a huge debt owed by a UK Company. Firm’s attempts in UK proceedings were commendable. Additionally, they also assisted in optimizing and reducing tax consequences both in the UK and in India emanating from recovery.”
Sumit GaralaSalus Product
“R & D Law Chambers has been a reliable and trustworthy source of advice for us. It is a one shot solution to all my queries-whether relating to business law, contracts or technology law.”
Puneet K. GoyalCo-founder, BLUSMART
“They don’t have a panacea for all my problems. however, they have been the most reliable in terms of quality of services in all areas and in terms of integrity. They know how to protect client’s interests.”
Dinesh HindujaEnprocon