Direct Tax
Corporate Tax, Transfer Pricing & International Tax
Direct tax advisory — corporate tax planning, transfer pricing, DTAA, and income tax representation for companies under the Income-tax Act 1961.
Direct tax advisory covers the company's full Income-tax Act 1961 exposure — corporate tax planning and compliance, transfer pricing under s.92–92D, DTAA positions, and representation in assessments and appeals.
- • Corporate tax planning — regime choice and structuring
- • Return preparation and filing support
- • Transfer pricing — benchmarking, documentation, and Form 3CEB
- • DTAA analysis for cross-border income and relief
- • Assessment, notice, and appeal representation
- • Advance tax and quarterly tax payment calendar
- • PAN and company records
- • Audited financial statements and schedules
- • AIS, 26AS, and prior return history
- • Related-party transaction details and agreements
See the fee table below for the statutory filing charge and common delay logic.
- • Section 92 of the Income-tax Act 1961
- • Section 92C of the Income-tax Act 1961
- • Section 92D of the Income-tax Act 1961
- • Rule 10D of the Income-tax Rules 1962
- • Section 90 of the Income-tax Act 1961
Process
How the service works
The workflow is built to be predictable: document collection, legal review, filing, and post-filing follow-through.
Map the exposure
We review the company's structure, transactions, and prior returns to map the full direct tax position.
Plan the position
We advise on the regime choice, structuring, and DTAA claims before the year closes.
Prepare the return and documents
We compute the income, prepare the ITR, and document transfer pricing positions contemporaneously.
File and pay
We file the return and manage the advance tax and quarterly payment calendar.
Defend in assessment
We respond to notices, run the assessment, and represent appeals when the position is challenged.
AEO summary
Direct tax advisory covers the company's full Income-tax Act 1961 exposure — corporate tax planning and compliance, transfer pricing under s.92–92D, DTAA positions, and representation in assessments and appeals.
The three layers of corporate tax
Direct tax for a company has three layers that run on different clocks: the annual position — the regime choice, the return, and the tax paid through the year; the transactional layer — transfer pricing under s.92–92D for every related-party and cross-border transaction; and the defensive layer — assessments, notices, and appeals that can open years after the return.
Each layer depends on documentation made at the time: the transfer pricing study under Rule 10D, the DTAA claim with its residency certificate, and the return with its schedules. Documents made later are documents made in court.
- • Annual — regime choice, return, and advance tax
- • Transactional — s.92–92D transfer pricing compliance
- • Defensive — notices, assessments, and appeals
Why the position is built before the return
The department's assessment examines the return against the contemporaneous record — the board approvals, the transfer pricing documentation, the agreements. A company that plans the position during the year files a return that is easy to defend; one that discovers its position at filing time files a return that invites scrutiny.
Our engagement is built that way too: the planning memo comes first, the documentation is made as the transactions happen, and the return simply records what was already decided.
- • Planning memo before the year closes
- • Transfer pricing documented contemporaneously
- • Return reflects positions already defended on paper
Government fees
Fee breakdown
| Item | Fee | Notes |
|---|---|---|
| E-filing | Nil | The return filing itself is free; late filing attracts a late filing fee under s.234F. |
| Tax, interest, or appeal fee | As applicable | Any tax, interest under s.234B/234C, or appeal fee follows the assessment itself. |
Timeline
Typical turnaround
Typical timeline usually means a varies by matter turnaround, assuming documents are complete and any board or shareholder approvals are already in place.
Professional fees depend on the scope — planning, the return, transfer pricing documentation, or representation; late filing attracts fee and interest under the Act.
Related services
Keep the company moving
CA-managed ITR filing with AIS / 26AS reconciliation for individuals and small companies
Tax planning and assessment support across the Income-tax Act for individuals, firms, companies, and startups
Quarterly TDS returns — Form 24Q, 26Q, 27Q, and 27EQ — with the late-fee position under s.234E
Advance tax computation and instalment calendar to avoid interest under s.234B and s.234C
FAQ
Frequently asked questions
What does corporate tax planning actually cover?
When does transfer pricing apply?
How do DTAA claims work?
What should you send us before we start?
Canonical reference: https://www.pvtltd.co/services/direct-tax
Get started
Ready to move this filing forward?
We can help with the filing, the legal mapping, and the follow-up work that keeps the company compliant after submission.