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 dispute resolution, income tax planning and litigation, regulatory filing management, and cross-border tax advisory for businesses operating across India and internationally.
Overview
Proactive Compliance Is Always Cheaper Than Reactive Defence
Every business decision has a tax dimension. Transactions that are commercially sensible can be structured in ways that reduce tax exposure — or structured carelessly in ways that create it.
Our regulatory compliance practice covers SEBI-regulated entities, RBI-licensed businesses, and sector-specific regulation across fintech, healthcare, and manufacturing.
Digital & AI Tax Advisory
Tax Questions in the Digital Economy
How is income from AI-generated services taxed? What are the transfer pricing implications of cross-border AI model use within a corporate group? How is GST applied to SaaS and AI-as-a-service offerings?
These questions affect a broad range of businesses — and require tax advice that is current with both law and revenue authority guidance.
in outstanding GST disputes currently pending across Indian courts and tribunals — most arising from structuring errors that specialist counsel would have prevented
Tax compliance is not a filing exercise. It is a risk management discipline.
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, and 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.
Transfer Pricing & International Tax
Transfer pricing documentation, benchmarking analysis, APA applications, CbCR, BEPS compliance, cross-border transaction structuring, and FEMA regulatory 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.
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.
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.
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.
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💰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.
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⚖️Litigation Experience
From ITAT appearances to High Court tax matters — our litigation team has experience across all tax tribunals and courts in India, providing continuity between advisory and dispute resolution.
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🔒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.
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🌐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.
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.
Structuring & Planning
Tax-efficient structuring recommendations, ITC optimisation, transfer pricing documentation review, regulatory compliance calendar design, and advance ruling strategy where applicable.
Compliance Management
Monthly/quarterly filing support, GST return filing, TDS management, regulatory filing coordination, and proactive department correspondence management.
Dispute Resolution
Assessment defence, demand response, appeal filing, ITAT/High Court representation, and settlement negotiation — with the same counsel who designed your compliance strategy.
Services Offered
What All We Handle
- Income tax advisory — corporate and individual
- GST compliance, audit, and dispute resolution
- Tax structuring for transactions — M&A, JVs, real estate
- Transfer pricing advisory and documentation
- FEMA compliance — FDI, ECB, ODI, NRI remittances
- SEBI compliance — disclosure, insider trading, licensing
- RBI regulatory compliance — NBFC, payment systems, forex
- Statutory compliance calendar management
- Government notice response and investigation defence
- Representation before ITAT, CESTAT, High Court
- Cryptocurrency and digital asset tax advisory
- Tax treatment of AI-generated income and cross-border AI services
- Tax-efficient corporate restructuring
- Director and officer liability advisory
Client Benefits
Why Clients Choose SIRI Law LLP
Pre-Transaction Tax Advisory
We advise before deals are structured — not after. Early tax planning prevents expensive post-transaction surprises.
Regulatory Investigation Experience
Our team has represented clients before SEBI, RBI, IT Department, and GST authorities.
Cross-Border Expertise
FEMA, treaty relief, and transfer pricing expertise for businesses with international operations or investors.
Digital Economy Specialists
Ahead-of-curve advisory on cryptocurrency, digital services tax, and AI-related income.
Representative Matters
Typical Engagements
All matters described generically to protect client confidentiality.
GST Dispute Resolution
Represented a manufacturing company in a GST dispute involving classification of composite supply — secured a favourable ruling, avoiding a ₹1.2 crore demand.
FEMA Compliance – Inbound FDI
Advised a technology company on a Series B funding round involving foreign investors — ensuring FEMA filings, valuation compliance, and RBI reporting within prescribed timelines.
Tax Structuring – Property Transaction
Advised a developer on tax-efficient structure for a large land acquisition — reducing stamp duty and capital gains exposure through lawful structuring.
Cryptocurrency Tax Advisory
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.
What to Expect
Client Outcomes
Defensible Compliance Position
Our work produces documented, auditable records — so when regulators enquire, clients have evidence of diligence, not just assertions.
Reduced Tax Exposure Through Structure
Clients receive transaction structures that achieve commercial goals while minimising lawful tax exposure — consistently and systematically.
Effective Regulatory Response
When notices arrive, our experience with each relevant authority means responses are calibrated correctly — neither over-conceding nor antagonising.
Case Study · GST Classification Dispute
SaaS company successfully defends ₹2.3Cr GST demand
on software licensing classification.
A Hyderabad SaaS company received a ₹2.3Cr 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.
The SIRI Difference
Without SIRI vs. With SIRI.
Chartered accountant or generalist tax firm
Filing without planning
Tax returns filed to comply, not to optimise — leaving material ITC claims, deductions, and structuring opportunities unclaimed across financial years
Technology transactions misclassified
GST classification of software, SaaS, and digital services handled using standard templates — frequently producing incorrect positions that only surface in assessments
No litigation capability
Advisory and compliance work handled in-house; disputes referred to a separate law firm with no familiarity with the underlying filing history and structuring decisions
Investigation response delayed
Tax survey or search response managed by the CA or internal team, without specialist legal investigation defence expertise — creating evidentiary risks
SIRI Law LLP — Advisory + Litigation
Proactive tax planning integrated with compliance
Every filing cycle reviewed for optimisation — ITC maximisation, deduction planning, and structuring adjustments made before positions are filed, not after they are challenged
Technology tax specialisation
GST and income tax classification of technology transactions handled by specialists with deep knowledge of CBIC circulars, advance rulings, and technology-specific precedents
Continuity from advisory to litigation
The same team that designed your tax positions appears in your dispute proceedings — no knowledge gap between compliance history and dispute strategy
Immediate investigation defence
Tax survey and search response managed by SIRI from the first day — document privilege established, officer interactions controlled, and defence strategy implemented immediately
Frequently Asked Questions
Taxation and regulatory compliance,
answered directly.
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.
📞 +91 7981912046 — Mon–Sat, 9 AM – 7 PM IST · WhatsApp