Tax Disputes
Income Tax & GST
Overview
Our tax practice advises and represents individuals, families, professionals and businesses in income-tax and Goods and Services Tax matters, from the first reply through appeals before the appellate authorities, the Tribunals and the High Court. What was once sales tax work is now largely GST work: since 1 July 2017, GST has replaced most state sales tax, along with central excise and service tax on most goods and services. State VAT and central sales tax still apply to a narrow group of goods, chiefly certain petroleum products and alcoholic liquor for human consumption, and older VAT-era assessments still come up.
Income tax is also in transition. The Income-tax Act, 2025 replaced the Income-tax Act, 1961 from 1 April 2026. It renumbered the provisions and replaced the separate 'previous year' and 'assessment year' with a single 'tax year'. Income of years that began before that date is still, broadly, governed by the 1961 Act, so for some time many taxpayers will have matters running under both statutes. We check which law applies to which year at the outset, because an error there can cost a limitation defence or a right of appeal.
Scope
What we handle.
Assessments and scrutiny
Replies to notices in scrutiny and faceless assessment, written submissions supported by documents, and requests for a personal hearing where the record calls for one.
Reassessment notices
Examining whether a notice to reopen a past year was issued in time, with the required approval and on information that legally justifies reopening. We reply at the show-cause stage and, where appropriate, challenge the notice before the High Court.
Search, seizure and survey
Advice during and after search and survey operations on recorded statements, seized material, the block assessment that follows a search, and related penalty proceedings.
Income-tax appeals
First appeals before the Joint Commissioner (Appeals) or Commissioner (Appeals), appeals to the Income Tax Appellate Tribunal, applications for stay of demand, and appeals to the High Court on substantial questions of law.
GST show-cause notices and demands
Replies to show-cause notices and demand proceedings on questions of limitation, input tax credit, classification and valuation, and on whether an allegation of fraud or suppression is supported by the record.
GST appeals and the Appellate Tribunal
Appeals before the GST Appellate Authority and the GST Appellate Tribunal, now sitting through Principal and State Benches, and writ petitions before the High Court where a proceeding lacks jurisdiction or breaches natural justice.
Legacy VAT and sales tax
Pending and residual matters under the Uttar Pradesh Value Added Tax Act, 2008 and the Central Sales Tax Act, 1956, including goods that remain outside GST.
Prosecution defence
Defence of prosecution complaints under the income-tax and GST laws, applications for compounding where the law allows it, and coordinated advice where tax proceedings overlap with investigations under other statutes.
Approach
How we approach a matter.
- Step I
Reading the notice
We establish which statute and which year apply, the time limits running against each side, and exactly what the department alleges. Jurisdiction and limitation are tested first, since a defect there can decide the matter.
- Step II
Assembling the record
Books, returns, bank statements, contracts and correspondence are gathered and reconciled, working with the client's accountant, so that every factual statement in a reply is supported by a document.
- Step III
Replying with the appeal in view
Submissions are written to persuade the assessing or proper officer. They are also written to preserve every ground and every piece of evidence for the appellate forums, where fresh material is admitted only in limited circumstances.
- Step IV
Carrying the matter through
If an order goes against the client, we advise plainly on whether an appeal is worth pursuing, on stay of demand and pre-deposit, and on the forum and timeline that follow.
Questions
Questions clients ask.
Which law applies now: the Income-tax Act, 1961 or the Income-tax Act, 2025?
The 2025 Act applies from 1 April 2026, to income of tax year 2026-27 onwards. Income of years that began before that date, including the year that ended on 31 March 2026, is still broadly governed by the 1961 Act, and appeals already pending continue under it. Because the provisions have been renumbered, a notice may cite either statute. Checking that it cites the right one is among the first things we do.
I have received a notice proposing to reopen an old assessment. What should I do?
Do not ignore it, and note the date by which a reply is due. The law limits how far back an assessment can be reopened. It generally requires the officer to share the information relied on and to give you an opportunity to respond before a reassessment notice is issued. Whether the notice is within time, properly approved and based on relevant information are legal questions to examine before you reply on the facts.
How long do I have to appeal against an income-tax order?
Not long. A first appeal must ordinarily be filed within thirty days of service of the order or demand notice. The periods for later appeals to the Tribunal and the High Court are measured in weeks or months, not years. Delay can sometimes be condoned for sufficient cause, but that is at the forum's discretion and should not be relied on.
Has the GST Appellate Tribunal started functioning?
Yes. The Tribunal's online filing portal opened in September 2025, and its Principal and State Benches began hearing matters in phases during 2026. Special transitional deadlines were set for appeals against older orders, and those windows have now closed. Appeals against fresh orders follow the ordinary time limit, which for a taxpayer is three months from the date the order is communicated. If you believe a deadline was missed, take advice promptly on whether the delay can still be condoned.
Does it matter whether a GST notice alleges fraud?
Yes. For tax periods up to 2023-24, the CGST Act set different time limits depending on whether fraud, wilful misstatement or suppression of facts was alleged. For periods from 2024-25 onwards, a single provision sets a common time limit for both kinds of case. The distinction still matters for penalty: where fraud is not alleged, paying the tax and interest within the period allowed after the notice can close the proceedings without a penalty. Whether the record actually supports an allegation of fraud is often the central question.
Can a tax matter lead to criminal prosecution?
It can. Both the income-tax and GST laws create offences, such as wilful attempts to evade tax or issuing invoices without any actual supply of goods or services. Prosecution may be launched separately from assessment. The outcome of the tax proceedings can bear on the prosecution, and some offences can be compounded, so the two should be handled together.
Principal statutes
- Income-tax Act, 2025 (in force from 1 April 2026)
- Income-tax Act, 1961 (repealed from 1 April 2026; continues to govern earlier years)
- Central Goods and Services Tax Act, 2017
- Integrated Goods and Services Tax Act, 2017
- Uttar Pradesh Goods and Services Tax Act, 2017
- Uttar Pradesh Value Added Tax Act, 2008
- Central Sales Tax Act, 1956
- Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015
Where these matters are heard
- Assessing Officers and faceless assessment units of the Income Tax Department
- Joint Commissioner (Appeals) and Commissioner (Appeals)
- Dispute Resolution Panel
- Income Tax Appellate Tribunal
- Central and State GST adjudicating authorities
- GST Appellate Authority
- GST Appellate Tribunal (Principal and State Benches)
- Criminal courts trying tax prosecutions
- High Court of Judicature at Allahabad and High Court of Delhi
- Supreme Court of India
Begin with a conversation.
A consultation of about an hour with an advocate of the firm, to understand your position and the options open to you. Fees are discussed and agreed beforehand.