Taxation & regulatory compliance law in Hyderabad — tax disputes cost more than tax planning. We do both.
Proactive tax counsel prevents the disputes that reactive tax counsel must survive. SIRI Law LLP's taxation practice provides integrated tax advisory and regulatory compliance — GST structuring and GSTAT dispute resolution, income tax planning and litigation, regulatory filing management, and cross-border tax advisory.
Why 2026 changes the tax dispute calculation
The appellate route that didn't exist for eight years is suddenly operational — and has a deadline.
For most of the GST era, taxpayers who lost at the first appellate stage had one real option left: an expensive, slow High Court writ petition. The GST Appellate Tribunal, created by Section 109 of the CGST Act back in 2017, was struck down by a constitutional challenge over how its members were composed and sat effectively non-functional for the better part of eight years. That gap is now closing. GSTAT became operational in 2025 and is expanding to additional state benches through 2026, and an estimated four lakh appeals accumulated during the dysfunction now have a genuine pathway forward.
That pathway comes with a hard deadline that a lot of businesses are not tracking. Backlog appeals — where the First Appellate Authority's order was communicated before 1 April 2026 — must be filed by 30 June 2026. After that, the normal three-month limitation period applies to fresh orders, with no indication of any further extension. Any company sitting on an adverse first-appellate order from the past several years needs to audit that backlog now, not after the window closes.
On the planning side, the news is more straightforwardly positive. The Finance Act 2025 extended Section 80-IAC's startup tax holiday — a 100% profit deduction for three consecutive years within the first ten — to startups incorporated before 31 March 2030, five years later than the original cutoff. Over 3,700 startups have been granted this exemption since the scheme's inception, with 187 approved in a single Inter-Ministerial Board meeting in April 2025 alone. One detail founders consistently miss: Minimum Alternate Tax under Section 115JB still applies during the holiday period, at 15% of book profits — the deduction reduces income tax liability, not the MAT obligation, and planning around the holiday needs to account for that cash outflow.
Where tax exposure quietly builds
Tax compliance is not a filing exercise. It is a risk management discipline.
These are the recurring patterns behind the disputes and assessments SIRI's tax practice handles most often — usually preventable with the right structuring in advance.
GST input credit disputes create cash flow crises
Incorrect ITC claims, vendor non-compliance, e-way bill errors, and GST return discrepancies trigger assessments and demands that create immediate cash flow pressure on businesses operating on thin margins.
Technology transactions have complex tax implications
SaaS subscriptions, digital services, and cloud computing carry specific GST classification questions that generalist tax advisers frequently mishandle, creating underpaid tax liability and interest exposure.
Transfer pricing requires technical documentation
Cross-border transactions between related entities require contemporaneous transfer pricing documentation. Inadequate documentation shifts the burden of proof in assessments to the taxpayer.
Regulatory penalties compound quickly
Income Tax, GST, TDS/TCS defaults, and regulatory filing failures each carry their own penalty structures. Without a systematic compliance calendar, defaults compound across multiple obligations simultaneously.
What we cover
Taxation and regulatory compliance across all major tax heads
From GST advisory and income tax planning through transfer pricing, investigation defence, and regulatory compliance management.
GST Advisory & Dispute Resolution
GST structuring, ITC optimisation, classification advice, return filing support, department correspondence management, assessment defence, appeal proceedings including GSTAT, and advance ruling applications.
- GST structuring and ITC optimisation
- Assessment and demand defence
- First appeal and GSTAT representation
- Advance ruling applications
Income Tax Planning & Litigation
Tax-efficient business structuring, MAT advisory, DTAA application, assessment proceedings, CIT(A) appeals, ITAT representation, and High Court and Supreme Court tax litigation.
- Tax-efficient structuring and MAT advisory
- DTAA treaty relief application
- CIT(A) and ITAT representation
- High Court and Supreme Court litigation
Transfer Pricing & International Tax
Transfer pricing documentation, benchmarking analysis, APA applications, CbCR, BEPS compliance, cross-border transaction structuring, and FEMA regulatory advisory.
- Master File and Local File documentation
- APA applications and benchmarking
- CbCR and BEPS compliance
- FEMA cross-border advisory
Regulatory Compliance Management
Annual compliance calendars, advance tax management, TDS/TCS compliance, regulatory filing coordination across MCA, SEBI, and RBI, reducing default and penalty exposure.
- Annual compliance calendar design
- TDS/TCS compliance management
- MCA, SEBI, and RBI filing coordination
- Advance tax planning
Startup & Technology Tax Advisory
Section 80-IAC startup tax exemptions, ESOP tax planning, digital economy tax classification, SaaS GST compliance, and tax-efficient structuring for technology companies.
- Section 80-IAC eligibility and IMB application
- ESOP tax planning
- SaaS and digital economy GST classification
- MAT planning during the tax holiday
Tax Investigation Defence
Income Tax survey and search defence, CGST audit response, SFIO investigation support, and regulatory enquiry management, with evidence preservation under legal privilege from day one.
- Survey and search response
- CGST audit defence
- SFIO investigation support
- Privileged evidence preservation
Evidence, not guesswork
The GSTAT appellate chain — what it actually costs and how long it takes
Most guidance on GST disputes glosses over the practical mechanics. Here's what the appellate chain looks like now that GSTAT is operational.
| Stage | Pre-deposit required | Typical timeline |
|---|---|---|
| First Appellate Authority | 10% of disputed tax | Filed within statutory window from order communication |
| GST Appellate Tribunal (GSTAT) | Additional 20%, capped at ₹20 crore per enactment | 3 months to file; 24–36 months to disposal |
| High Court | No separate pre-deposit; only for substantial questions of law | GSTAT findings of fact cannot be reopened here |
| Backlog appeals (pre-1 Apr 2026 orders) | Same as above | Must be filed by 30 June 2026 |
Sources: CGST Act Sections 109 and 112; GSTAT procedural guidance as of 2026; industry commentary on GSTAT bench operationalisation. Pre-deposit caps and deadlines are subject to further notification — confirm current figures before relying on them for a specific matter.
What the numbers actually mean
Four figures that frame the tax dispute landscape today
Estimated backlog accumulated before First Appellate Authorities during GSTAT's eight years of dysfunction — now with a pathway and a deadline.
Per enactment (CGST and SGST separately) — a material cash flow figure for any high-value dispute considering the appellate route.
Since the scheme's inception, with 187 approved in a single April 2025 Inter-Ministerial Board meeting alone.
Minimum Alternate Tax on book profits still applies during the Section 80-IAC three-year deduction window — a commonly missed planning detail.
How we engage
Four stages from briefing to resolution
A structured engagement that moves from risk identification through compliance design to ongoing management and dispute resolution.
Tax health check
Comprehensive review of current tax filing positions, open disputes, compliance calendar, and structuring, identifying immediate risks and optimisation opportunities across all applicable tax heads.
Week 1Structuring & planning
Tax-efficient structuring recommendations, ITC optimisation, transfer pricing documentation review, regulatory compliance calendar design, and advance ruling strategy where applicable.
Weeks 2–4Compliance management
Monthly and quarterly filing support, GST return filing, TDS management, regulatory filing coordination, and proactive department correspondence management.
OngoingDispute resolution
Assessment defence, demand response, appeal filing, ITAT and GSTAT representation, and settlement negotiation, with the same counsel who designed your compliance strategy.
As neededCase study · GST classification dispute
SaaS company successfully defends ₹2.3 Cr GST demand on software licensing classification
A Hyderabad SaaS company received a ₹2.3 crore GST demand challenging the classification of its software subscription services. SIRI Law LLP's technology tax team compiled a comprehensive classification defence supported by advance ruling precedents, CBIC circulars, and technical documentation of the service delivery model.
The demand was set aside at first appeal — resolved without proceeding to GSTAT, a result made possible by building a technically credible classification argument from the outset rather than a generic filing-template response.
Representative matters
Typical engagements
All matters described generically to protect client confidentiality.
Composite supply classification
Represented a manufacturing company in a GST dispute involving classification of composite supply, securing a favourable ruling and avoiding a ₹1.2 crore demand.
Series B funding round
Advised a technology company on a Series B funding round involving foreign investors, ensuring FEMA filings, valuation compliance, and RBI reporting within prescribed timelines.
Land acquisition structuring
Advised a developer on a tax-efficient structure for a large land acquisition, reducing stamp duty and capital gains exposure through lawful structuring.
VDA regime compliance
Advised a high-net-worth individual on the tax treatment of cryptocurrency gains under India's 30% VDA regime, including cost basis documentation and TDS compliance.
Why SIRI
Tax counsel with regulatory and technical depth
SIRI Law LLP advises technology, FinTech, and digital economy companies on tax questions that generalist advisers cannot answer — classification of software transactions, SaaS international tax, and digital services GST.
Proactive tax planning
We structure transactions to maximise tax efficiency before filing, not after assessments have been raised. Our advisory regularly identifies material savings in GST structuring and income tax planning.
Litigation experience
From ITAT appearances to GSTAT and High Court tax matters, our litigation team has experience across all tax tribunals and courts in India, providing continuity between advisory and dispute resolution.
Investigation defence
Tax surveys and searches require immediate specialist response. SIRI deploys immediately, establishing legal privilege over documents and developing the defence strategy from the first day.
Technology tax specialisation
GST classification of software, SaaS, API services, and digital content is one of the most complex and frequently disputed areas in Indian indirect tax law. SIRI's technology tax practice has resolved classification disputes that generalist advisers consistently get wrong.
The comparison
Without SIRI versus with SIRI
| Capability | Chartered accountant or generalist tax firm | SIRI Law LLP — advisory + litigation |
|---|---|---|
| Filing approach | Returns filed to comply, not to optimise — opportunities unclaimed across years | Every filing cycle reviewed for optimisation before positions are filed |
| Technology transaction classification | Handled with standard templates — errors surface only in assessments | Specialists with deep knowledge of CBIC circulars and technology-specific precedent |
| Litigation continuity | Disputes referred to a separate firm unfamiliar with the filing history | Same team that designed your tax positions appears in your dispute proceedings |
| Investigation response | Managed by CA or internal team without specialist legal defence expertise | Managed by SIRI from day one — privilege established, officer interactions controlled |
Frequently asked
Taxation and regulatory compliance, answered directly
What GST rate applies to SaaS and software subscriptions?
GST classification of software services is one of the most contested areas in Indian indirect tax law. The applicable rate depends on whether the supply is classified as goods, services, or mixed supply, with rates ranging from 12% to 18%. SIRI specialises in technology tax classification and has successfully defended several disputed positions.
What is the GST Appellate Tribunal and why does it matter now?
The GST Appellate Tribunal, created by Section 109 of the CGST Act, was effectively non-functional between 2017 and 2024 due to a constitutional challenge over its member composition. It became operational in 2025 and is expanding to additional state benches through 2026, restoring a genuine second-appeal route that previously forced taxpayers into expensive High Court writ petitions. An estimated four lakh appeals were pending before First Appellate Authorities during the gap, and the deadline to file backlog appeals for orders communicated before 1 April 2026 is 30 June 2026.
How much does it cost to appeal a GST demand through the full appellate chain?
A pre-deposit of 10% of the disputed tax is required to file the first appeal, and GSTAT requires an additional 20% pre-deposit, capped at ₹20 crore per enactment (CGST and SGST separately). For a ₹10 crore disputed demand, that is a cumulative, non-refundable pre-deposit of roughly ₹3 crore until final disposal — a cash flow commitment that should factor into any decision to litigate versus settle.
Can you help with startup tax exemptions under Section 80-IAC?
Yes. Following the Finance Act 2025, Section 80-IAC's 100% profit deduction for three consecutive years is now available to startups incorporated before 31 March 2030, an extension of five years from the original cutoff. Eligibility requires DPIIT recognition, a separate Inter-Ministerial Board certificate, and turnover under ₹100 crore in the relevant year — and Minimum Alternate Tax under Section 115JB still applies during the holiday, a detail that catches founders who assume the deduction means zero tax outflow entirely.
How should cross-border technology services be treated for Indian GST?
Imported technology services attract IGST under the reverse charge mechanism, payable by the Indian recipient. For Indian companies exporting technology services, zero-rating applies under the place of supply rules subject to specific conditions, including receipt of consideration in foreign exchange.
What should I do if I receive a GST notice or income tax assessment?
Respond promptly — most notices have statutory response deadlines. Before responding, engage specialist tax counsel to review the legal basis of the notice, the documents involved, and the appropriate defence strategy. Do not submit documents without counsel reviewing what privilege applies.
Ready when you are
Tax planning before the dispute is always less expensive than litigation after.
Book a confidential tax assessment with SIRI Law LLP. We will review your current tax positions, identify risks and opportunities, and design a compliance and planning strategy.
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Other ways SIRI Law LLP supports growing companies
Visit or contact us
SIRI Law LLP — Hyderabad, India
| Registered office | HITEC City, Madhapur, Hyderabad, Telangana 500081, India |
| Telephone | +91 79819 12046 |
| info@sirilawllp.com | |
| Other offices | New Delhi, India · Austin, Texas, USA · Online worldwide |
| Hours | Mon–Sat, 9:30 AM – 7:00 PM IST · Emergency line 24/7 |