Tax planning, controversy and defence for family-owned manufacturers.
We help owners make defensible tax decisions before a transaction, maintain cleaner compliance during the year and respond with evidence when the department asks questions.
Experience where the stakes are already high.
CA Samrat Joneja has represented manufacturing businesses before the Income-tax Department for resolution of disputes, including matters arising from Investigation Wing action and search-related proceedings.
He has also represented clients before the Commissioner of Income-tax (Appeals) and the Income Tax Appellate Tribunal. Each matter is approached through the facts, books, seized or impounded material where relevant, legal position, reconciliation trail and the procedural record.
Representation & dispute support
- Assessment and reassessment proceedings
- Search-related and Investigation Wing matters
- Responses to notices and information requests
- Evidence collation and financial reconciliations
- Submissions before CIT(A)
- Appeal support and representation before ITAT
- Penalty and prosecution-risk coordination with legal counsel where required
Scope depends on the proceeding, professional eligibility and whether specialist legal representation should be engaged.
Tax support from planning through appeal.
The objective is not aggressive tax reduction. It is a lawful structure, a credible return position and an evidence trail that can be explained years later.
Compliance & advisory
- Corporate tax computations and returns
- Advance-tax and cash-tax forecasting
- Tax audit coordination
- MAT, losses and regime comparisons
- TDS / withholding-tax reviews
- Year-end provision and deferred-tax support
Owner-level tax planning
- Entity and group-structure reviews
- Company and LLP formation or reorganisation
- Promoter remuneration and distribution planning
- Succession, family settlements and ownership changes
- Related-party arrangements
- Exit and capital-gains modelling
GST & indirect tax
- Return and books reconciliation
- Input-tax-credit risk review
- Job work, tooling and customer-supplied material
- Classification, place and time of supply
- Notices, audits and departmental proceedings
- Refund and working-capital issues
Assessments & appeals
- Notice strategy and response preparation
- Faceless and jurisdictional proceedings
- Search-related financial analysis
- CIT(A) submissions and representation
- ITAT case preparation and representation
- Penalty defence
Transfer pricing & cross-border tax
- Related-party transaction mapping
- Transfer-pricing documentation
- Financial benchmarking coordination
- Intercompany service and financing arrangements
- Withholding-tax analysis
- Permanent-establishment and treaty coordination
Transaction tax
- Share transfers and equity infusions
- Mergers, demergers and slump sales
- Business succession and family reorganisation
- Joint ventures and shareholder exits
- Valuation-linked tax provisions
- Pre-signing tax modelling
Tax planning that starts with ownership, cash flow and succession.
A manufacturing family should review the tax cost of the operating company and the tax path by which value reaches owners. The right answer changes as profits, borrowing, family participation and succession plans evolve.
Where disputes commonly begin.
Manufacturing creates high-volume evidence across purchasing, production, inventory, dispatch, customer pricing and vendor payments. Tax positions become vulnerable when those systems do not reconcile.
Inventory & consumption
Yield, scrap, obsolete stock, shortages, job work and differences between physical, ERP and financial records.
Related parties
Pricing, management services, rent, loans, guarantees, reimbursements and commercial substance.
Capital vs revenue
Tooling, repairs, development cost, technical know-how, trial runs, project expenditure and depreciation.
GST data trails
Turnover reconciliation, ITC eligibility, vendor defaults, e-invoices, e-way bills and credit notes.
Build the case from the records outward.
Good representation begins with a controlled fact pattern, not a generic legal note.
Identify exposure
Read the notice, order or transaction documents and identify immediate deadlines and information gaps.
Control the facts
Tie books, returns, bank data, agreements and departmental information to one explainable record.
Frame the response
Connect evidence to the applicable law, judicial position and procedural history.
Close each issue
File, appear where authorised, track hearings and preserve the record needed for the next appellate level.
Scope before strategy.
Do you take up search-related cases?
Yes, where the facts, records, timelines and professional scope can be properly evaluated. Matters may also require coordination with an advocate or other specialist.
Can tax planning be done after year-end?
Some compliance choices remain, but the best planning normally occurs before contracts, distributions, restructurings or capital expenditure are implemented.
Can you represent before CIT(A) and ITAT?
Yes, subject to engagement acceptance, the nature of the matter and applicable professional eligibility. Samrat has represented clients before both forums.
Start before the transaction—or before the response deadline.
Share the transaction summary or notice, relevant dates and the financial records available. We can identify the immediate workplan.