Direct Tax Practice
End-to-End Advisory, Compliance, and Dispute Resolution Across Corporate, Individual, and Cross-Border Tax Matters
Our Direct Tax practice delivers comprehensive, strategic, and forward-looking tax support to businesses, high-net-worth individuals, multinational groups, funds, and promoter families. CLC's team brings deep industry experience, technical expertise, and a solution-oriented approach to help clients navigate the evolving landscape of Indian taxation, global tax reforms, and multi-jurisdictional tax challenges.
We provide holistic advisory spanning corporate tax structuring, capital-market transactions, business reorganisations, cross-border tax planning, transfer pricing, and taxation of high-net-worth individuals, aligned with both commercial objectives and regulatory requirements. With an emphasis on long-term sustainability, risk mitigation, and tax efficiency, we guide clients through the complete lifecycle of tax planning, reporting, assessment, and litigation.
On the dispute side, our lawyers regularly appear before Assessing Officers, Commissioner (Appeals), the Income Tax Appellate Tribunal (ITAT), High Courts, and the Supreme Court in complex matters involving TP adjustments, treaty benefit claims, fund taxation, PE exposure, GAAR, corporate reorganisations, MAT disputes, and interpretation of tax statutes. Our strategic, data-driven representation ensures rigorous defence, persuasive advocacy, and successful outcomes in high-stakes matters.
Key Service Areas
Corporate & Individual Tax Advisory
- Structuring of business operations, investments, and asset transfers
- Capital gains advisory in shares, securities, real estate, slump sale, and business transfers
- Tax planning for HNIs, family offices, promoter families & investment entities
- Taxation of ESOPs, equity compensation & startup taxation matters
- Residency, remittance, exit tax, and cross-border mobility planning
Cross-Border Tax Structuring & International Tax
- DTAA interpretation, treaty relief planning & dispute support
- PE/Business Connection evaluations & documentation
- Guidance on global mobility, foreign subsidiaries & holding structures
- Outbound/inbound investment structuring
- Foreign remittance documentation (Form 15CA/CB) and treaty benefit certifications
Transfer Pricing
- TP planning, benchmarking & documentation
- Defence during audits, review, and assessments
- Representation in TP disputes before DRP, ITAT, and Courts
- Advisory on inter-company agreements, shared services, IP licensing & cost-allocation models
Transaction Structuring & Reorganisations
- Tax-efficient mergers, demergers & business restructuring
- Profit repatriation structures-dividends, royalties, buybacks, capital reduction, inter-company funding
- Start-up structuring & capital-raising tax strategy
- Evaluation under GAAR, POEM, and substance-based requirements
Tax Disputes & Litigation
- Representation before AO, CIT(A), DRP, ITAT, High Courts & Supreme Court
- Disallowances, re-openings, reassessments, and penalty disputes
- Constitutional challenges to tax provisions & retrospective amendments
- Litigation involving funds, permanent establishments, treaty interpretations & TP adjustments
Select Experience
- Advised the Government of India on a major bilateral tax treaty dispute involving complex cross-border income characterisation.
- Structured multi-layered tax-efficient cross-border flows and repatriation strategies for global conglomerates.
- Represented clients in high-value Transfer Pricing litigation involving intangibles, intra-group services & financial transactions.
- Assisted large Indian and multinational groups in reorganisations requiring GAAR/POEM analysis and treaty-efficient pathways.