"With over 15 years of practical experience as a Chartered Accountant, including positions at Big 4 firms, Suraj R. Agrawal has honed expertise in a wide array of tax-related areas. He specializes in global transfer pricing, cross-border transaction structuring, international taxation, tax structuring, double tax treaty issues, permanent establishment concerns, and the BEPS project, with a deep understanding of Indian and global transfer pricing benchmarking. Suraj focuses on transfer pricing and international tax advisory, design, documentation, and dispute resolution, including APAs. He assists leading multinationals with transfer pricing strategies, model designing, supply chain modelling, cross-border transaction advisory, compliance, tax due diligences, audits, tax planning, and global documentation studies. Suraj’s expertise covers a range of transactions, including tangible products, licensing of intangible assets, intercompany services, loans, and guarantees. He effectively represents clients at various levels, including CIT(A), DRP, and AO/TPO. Additionally, Suraj contributes to tax advice and solutions for multinational corporations, with regular features in forums such as Pune ICAI journals, WIRC journals, Taxguru, Taxmann, and TaxSutra. He also shares his knowledge through presentations at various forums, earning a reputation as a reliable and trusted professional in the field of taxation. "
Explore the Ayodhya Rami Reddy Alla vs PCIT case, delving into GAAR vs SAAR implications. Understand the Telangana High Court’s ruling on tax avoidance and the invocation of GAAR.
Tribunal upholds CIT(A) decisions in DCIT Vs Astral Limited case, offering key insights on TP adjustments, ESOP expenses, and Section 14A disallowance.
Explore the implications of the PCIT Vs I.A. Hydro Energy case regarding loan conversion to equity under Section 56(2)(viib) of the Income Tax Act, 1961, highlighting the choice of valuation method with the assessee.
Learn about carry forward and set off of losses in case of closely held companies under Section 79. Understand the conditions for carrying forward losses and make informed financial decisions.
Carry Forward and Set Off of Accumulated Business Losses and Unabsorbed Depreciation in Certain Cases of Amalgamation, Demerger, Re-organisation of business & Conversion of a company into LLP
Aban Offshore Limited Vs Addl. CIT (Madras High Court) Case Summary: – Facts of the case: ♦ The Assessee, Aban Offshore Limited, engaged in providing oil field services to various oil majors for offshore exploration and production of hydrocarbons in India and abroad, is a regular Assessee in terms of the provisions of the Indian […]
Smt. Anita Sunil Mahajan Vs ACIT (ITAT Pune) Definition of ‘relative’ for Specified Domestic Transactions (SDTs) should be as per Section 2(41) of Income Tax Act, 1961 and Section 56(2)(v) would not apply. Case Summary: – Facts of the case: During AY 2013-14, Smt. Anita Sunil Mahajan (Assessee), filed her return declaring total income at […]
Section 92 of the Income Tax Act deals with any income or expense arising from an ‘International Transaction’. In order to understand the definition of ‘International Transaction’, it is essential to understand the definition of ‘Transaction’. Clause (v) of Sections 92F of the Act defines a transaction as: Section 92F of the Act provides an […]
GVV Construction Pvt. Ltd. Vs. DCIT (ITAT Cuttack) If the assessee uses motor lorries partly for own use and for hire charges he is not entitled to claim excess depreciation @ 30% as per the provisions of Section 32 of the Income Tax Act. Case Summary: – Facts of the case: The assessee filed return […]
Lonsen Kiri Chemical Industries Ltd. Vs DCIT (ITAT Ahmadabad) Once the comparable company becomes the AE of the assessee in the year under consideration, then such company cannot be considered for the purpose of comparable. Case Summary: – Facts of the case: The assessee is a joint venture of two companies namely Well Prospering Ltd […]
