Debojit Mahanta

Transaction advisory

• Assisting clients with advisory and implementation on India entry strategy which inter-alia include advising on funding options and related income-tax implications, tax impact on possible holding structure including repatriation of profits, advising on supply chain models to ensure compliance with Indian tax and regulatory laws, discussions with Indian JV partners on proposed term sheet and related tax implications
• Advising clients on India outbound investments in view of extant foreign exchange control regulations, income-tax implications. This also involves project management in terms of liaising with lawyers/tax consultants of foreign jurisdiction to determine entity form, jurisdiction, transfer pricing implications, repatriation options
• Advising clients on tax and regulatory implications on varied domestic and cross-border transactions involving interpretation of domestic income-tax laws and applicable provisions of double taxation avoidance agreements.
• Advising and assisting clients with India level group reorganizations. This includes income-tax advisory and implementation assistance in relation to various modes of business realignment such as slump sale of undertaking, share transfer, itemized transfer of assets, succession of business etc.
• Assisting clients with preparation of case for opinion for seeking views from Senior Counsels, Retired judges on complex issues such as applicability of Equalization Levy, issues arising on conversion of sole proprietorship concern into company, recognition of intangibles for tax depreciation etc.
• Assisting clients with Permanent Establishment exposure risk evaluation and advising on mitigating steps in scenarios such as secondment, marketing support arrangement etc.
• Advising and assisting clients in obtaining lower withholding tax (TDS) certificate from Income-tax Department.

Tax compliance management:

• Managing income-tax compliances for clients involving determination of monthly tax deducted at source (TDS) to be deposited, filing of quarterly TDS returns, assisting in advance tax computation, filing of Statement of Financial Transactions etc.
• Project management of entire tax function involving Goods and Services Tax (GST) transfer pricing compliances for clients under managed services model
• Assisting clients in review of computation of taxable income by evaluating positions adopted basis judicial precedents, preparation and filing of income tax return (ITR)

Tax dispute resolution:

• Assisting clients in terms of strategy and filings pursuant to notices issued during tax audit/assessment proceedings. This inter-alia include preparation of technical submissions on show cause notices, appearing before Assessing Officers for hearing, filing stay of demand applications etc.
• Assisting clients with drafting of grounds of objections against draft assessment orders and representing clients in hearings before Dispute Resolution Panel.
• Assisting clients with filing appeals before appellate authorities such as CIT(Appeals), Income Tax Appellate Tribunals, High Court and preparation of synopsis of arguments to be perused by arguing Counsels.
• Strategizing filing of Writ Petitions on issues such as re-assessment, non-processing of refunds etc. including preparation of draft Writ petitions, rejoinders and briefing Counsels.
• Advising clients on adoption of alternative dispute resolution mechanisms such as Mutual Agreement Procedure, Advance Pricing Agreements or filing application for advance ruling before erstwhile Authority of Advance Ruling
• Assisting clients on strategy to be adopted for expediting processing of refunds which inter-alia involves representation before Income-tax department.

Others:

• Assisting in writing published articles on topical issues such as VDA taxation, Union Budget related changes, tax dispute resolution etc.
• Undertake Firm wide trainings on topical issues such as taxation of digital economy
• Assisting reporting Partner on preparation of briefing documents on relevant issues for discussion with industry forums such as OECD 2 Pillar framework, tax implications due to pandemic etc.
• Manage team of four tax professionals directly and project manage wider team for assignments undertaken with other Partners and Directors