Aayushi Gala
Mumbai
Summary
Experienced professional in transfer pricing services, with a strong background in intercompany transactions, compliance documentation and tax planning. Skilled in rapidly acquiring new knowledge and applying it effectively. Driven by a passion for continuous learning and successfully navigating change.
Overview
2026
2026
years of professional experience
Work History
Senior - Global Transfer Pricing Dept
BBSR & Associates LLP (KPMG Affiliate)
02.2023 - Current
- Assisted in advisory assignments related to business restructuring, determining the applicability of the exit charge.
- Conducting reviews of intercompany agreements and providing comments to ensure alignment with tax regulations.
- Advised on SDT transactions under income tax provisions, including detailed functional and risk profiling, and ALP analysis for domestic related-party transactions.
- Designing effective cost allocation methodologies for shared services and centralized functions, backed by robust allocation keys, along with documentation support.
- Determining applicability of secondary adjustments including tax implications, analysis of SEP provisions and advising on thin capitalisation.
- Conducted benchmarking analysis from an OECD perspective for intercompany transactions undertaken in overseas jurisdictions, interest on loan transactions and royalty transactions.
- Providing valuable support in the litigation process including drafting appeal sets, stay applications, legal and factual paper books, attending ITAT and DRP hearings and drafting responses to notices issued by the TPO and CIT(A).
- Prepared and reviewed Form 3CEB reports in compliance with Indian Transfer Pricing Regulations for clients across various industries including manufacturing, software, IT/ITeS, investment management/advisory, aviation, ship-management, miscellaneous services.
- Facilitated the preparation of Master File Part A and Part B (Form 3CEAA and Form 3CEAB) and assisted in preparation of CbCR (Form 3CEAC) for entities in diverse industries.
- Drafted comprehensive TP study reports including conducting in-depth FAR analysis for new clients/service segments.
- Assisted in preparation and filing of APA application in Form 3CED and filing of renewal application in Form 3CEDA.
Article Assistant
CNK & Associates LLP
- Running searches on softwares viz. Capitaline, Prowess, AceTP along with preparing the search strategy, accept reject matrix, industry overview, conducting quantitative and qualitative analysis and computing margins for comparable companies.
- Detailed analysis of royalty and fees for technical services under the Act and DTAAs, along with preparation of Form 15CA and 15CB for withholding compliance u/s 195.
- E-filing ITRs of companies, trusts, partnership firms, individuals (including NRIs).
- Preparing responses for submission before various tax authorities, assisted in the drafting and filing of tax appeals before CIT(A) and ITAT and preparation of paperbooks for ITAT proceedings.
Education
Chartered Accountant - 425/800 (Elective Subject - International Tax)
Institute of Chartered Accountants of India
11-2022
M.Com (First Class) -
H.R. College of Commerce & Economics
03-2021
B.Com (CGPA 8/10) -
H.R. College of Commerce & Economics
03-2019
Skills
- KPMG Spot Award (November 2024)
- KPMG Kudos Award (November 2023)
- 'Most Dedicated Member towards Community Services for FY 14-15' - Rotaract Club of HR College of Commerce & Economics
- Outstanding Member for the months of October, November, December 2014 and January, March 2015 - Rotaract Club of HR College of Commerce & Economics
Timeline
Senior - Global Transfer Pricing Dept
BBSR & Associates LLP (KPMG Affiliate)
02.2023 - Current
Article Assistant
CNK & Associates LLP
Chartered Accountant - 425/800 (Elective Subject - International Tax)
Institute of Chartered Accountants of India
M.Com (First Class) -
H.R. College of Commerce & Economics
B.Com (CGPA 8/10) -
H.R. College of Commerce & Economics
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