When the notice arrives, we arrive with it.
Income-tax assessments, GST audits and demands, customs disputes, ROC adjudications, EPF / ESI inquiries, faceless appeals and tribunal representation — handled by senior advocates and chartered accountants who have done it for two decades, not delegated to interns who learn at your cost.
- Income-tax — Faceless Assessment
- Income-tax — CIT(A) / ITAT
- GST — Adjudication / Appeals
- Customs & FEMA disputes
- MCA / ROC adjudication
- EPF, ESI & Labour
- Search, Survey & Seizure
A demand is not a verdict. Most are reversed on appeal.
Indian tax and regulatory enforcement runs on automated triggers, departmental targets and ambitious assessment orders. Most demands are partially or fully reversible — at the CIT(A) faceless stage, the ITAT, the Commissioner (Appeals) GST or the High Court. The single biggest determinant of outcome is not the law (that does not change much) but the quality of the response, the discipline of the documentation and the persistence of representation across hearings.
Zfiling\u2019s litigation practice is led by chartered accountants and advocates with combined experience across hundreds of assessment orders, faceless appeals, ITAT, GSTAT, CESTAT and writ matters. We have argued before settlement commissions, vivad-se-vishwas schemes, GST advance ruling authorities and the High Court. The aim, always, is to close the matter at the lowest possible level — most disputes should not reach the tribunal in the first place.
We also build litigation hygiene into ongoing engagements — proper position papers, contemporaneous documentation, tax-position memos and contract drafting that reduce future exposure. The cheapest litigation is the one that never starts.
Seven specialised practices for seven kinds of notice.
Each authority — income tax, GST, customs, MCA, EPF, ESI — has its own procedure, evidence standards, statutory time limits and culture of adjudication. The mistake of generalist representation is the most expensive one in any dispute.
Faceless assessment, reassessment & CIT(A) appeals
The faceless assessment regime under Section 144B has fundamentally restructured how income-tax assessments and appeals work — written submissions, video hearings, draft assessment orders, objections and final orders all run through the National Faceless Assessment Centre. The discipline now matters more than ever: every submission has to be drafted to stand alone, every annexure has to be self-evidently relevant, every fact has to be traceable to source.
We handle assessments under Section 143(3), reassessments under Section 147, search assessments under Section 153A, faceless penalty proceedings and first appeals before the CIT(A) — at both the rectification and substantive stages.
- Reply to notices under 142(1), 143(2), 148, 263
- Drafted submissions with case-law indexed and tabulated
- Video-conference hearings represented by senior partner
- Objections to draft assessment orders within 30-day window
- CIT(A) Form 35 appeal drafting + grounds + statement of facts
- Stay applications and rectification petitions
- Penalty defence under Sections 270A, 271 and 271AAB
ITAT & High Court — second appeals and writs
When the CIT(A) order is unfavourable, the next forum is the Income Tax Appellate Tribunal — a quasi-judicial body where matters are argued orally before a Member (Judicial) and Member (Accountant). The standards of pleading and oral argument are far higher than at the CIT(A) stage. A High Court writ is available where the order suffers from a jurisdictional error, denial of natural justice or perversity.
We file Form 36 ITAT appeals, draft statements of facts and grounds, prepare paper books, appear at oral hearings before the Bench in Delhi, Mumbai, Kolkata, Chennai and Bangalore, and conduct writ matters before the High Court — often jointly with senior counsel for matters of constitutional or jurisdictional importance.
- ITAT Form 36 appeal drafting + grounds + SoF
- Paper-book compilation + indexing to ITAT standards
- Oral representation by partner before the Bench
- Stay applications before ITAT + AO during pendency
- Misc. applications, rectification, condonation
- Cross-objections by the Revenue defended
- High Court writ + brief liaison with senior counsel
GST adjudication, demand orders & appeals
The GST regime is producing notices at industrial scale — Section 73 (normal cases), Section 74 (fraud / suppression), Section 65 (departmental audit), Section 67 (search and seizure) and now ASMT-10 scrutiny notices on a near-monthly cadence. The same factual matrix can attract demands across multiple states, multiple financial years and multiple sections in parallel.
We handle the entire arc — pre-notice consultations, replies to ASMT-10 and SCNs, attending hearings before the proper officer, drafting first appeals before the Commissioner (Appeals) and, increasingly, briefing matters for the GST Appellate Tribunal as benches roll out.
- ASMT-10 scrutiny notice replies + reconciliation evidence
- SCN replies under Sections 73 and 74
- Departmental audit (Section 65) — DRC-01A representation
- Personal-hearing representation before the proper officer
- Form GST APL-01 first appeal drafting + grounds
- Pre-deposit petitions and stay applications
- GSTAT readiness — early case theory + evidence preservation
Customs valuation, classification & FEMA disputes
Customs disputes typically arise on three axes — valuation (related-party transactions, royalty inclusion, post-import discounts), classification (HSN under which the goods fall) and applicability of exemption notifications. FEMA disputes — Liberalised Remittance Scheme breaches, ODI compliance failures, late ECB reporting, FDI-route violations — go before the Adjudicating Authority and the Appellate Tribunal under FEMA.
We represent before the SVB at Mumbai, JNCH and Delhi for valuation matters, draft replies to SCNs from the SIIB and CIU, appear before the Commissioner (Appeals) and CESTAT, and handle FEMA compounding applications before the RBI Compounding Cell.
- SVB (Special Valuation Branch) reply preparation
- Customs valuation enquiry replies + transfer-pricing alignment
- HSN classification disputes — CESTAT briefs
- EOU / SEZ / FTWZ compliance and exit-related disputes
- FEMA compounding applications to RBI
- Show-cause replies under FEMA before Adjudicating Authority
- ED enquiries — strategic legal support coordination
MCA / ROC adjudication & compounding
The MCA has dramatically expanded its adjudication activity — Section 454 adjudications for procedural breaches, Section 441 compounding applications for compoundable offences, NCLT petitions for oppression and mismanagement, scheme petitions and DIN disqualification matters. The amounts involved are often material — adjudication officers routinely impose lakhs of rupees per default.
We respond to adjudication notices, file compounding applications, defend show-cause notices from the ROC, handle DIN disqualification removal petitions and represent before the Regional Director, NCLT and NCLAT in corporate disputes.
- Section 454 adjudication notice replies
- Section 441 compounding applications + RD hearings
- Show-cause notice responses to ROC / Regional Director
- NCLT petitions — oppression, mismanagement, scheme
- DIN disqualification removal under Section 164
- CSR adjudication and Section 135 compliance defences
- Voluntary disclosure and condonation applications
EPF, ESI & labour law inquiries
EPF inquiries under Section 7A — the most under-defended bucket of social-security litigation in India. The EPFO is increasingly aggressive about contract-labour coverage, allowance-restructuring challenges and recovery proceedings on wage components. ESI demands operate on similar lines under Section 45A. Add Shops & Establishments inspections, Contract Labour Act enforcement and the new Code on Wages / Code on Social Security and the exposure compounds.
We represent before the PF Commissioner, ESI Commissioner, Labour Commissioner and the Industrial Tribunal — and defend matters at the EPFAT, ESIC Court and High Court when required.
- Section 7A EPF inquiry representation
- Wage-component challenges — basic vs. special allowance
- Coverage disputes — contract labour, principal employer
- Section 14B damages and Section 7Q interest defences
- ESI Section 45A determination orders defended
- Industrial Tribunal references and conciliation
- EPFAT and ESI Court second appeals
Search, survey, seizure & investigation defences
When the Income Tax Investigation Wing, GST Anti-Evasion or DGGI initiates a search under Section 132 or 67, the immediate 72 hours determine the next three years of litigation. Statements, panchnamas, seized documents, hard-disk images and admissions are the evidence base on which assessments are built. Senior advocates have to be on-site or available by video within hours.
We provide search defence, post-search assessment representation under Section 153A, statement retraction advisory, settlement applications under Section 245C (where available), DGGI summons compliance and prosecution defence under the Income Tax Act, Customs Act and the CGST Act.
- Search-day legal presence + senior partner phone access
- Statement and panchnama review for procedural defects
- Section 153A assessment defence (six prior years + search year)
- Settlement Commission applications (where available)
- DGGI summons attendance + recording supervision
- Prosecution defence under tax statutes
- PMLA / FEMA parallel-proceedings coordination
Any other service
you need.
Specialist forums and subject-matter disputes we routinely handle alongside the seven core practices — from advance rulings to constitutional writs.
A short, non-exhaustive list of other services we routinely deliver:
- Authority for Advance Rulings — Income Tax (BIAR) and GST (AAR)
- Appellate Authority for Advance Rulings — AAAR (GST)
- Settlement applications under the Direct Tax Vivad se Vishwas Scheme
- Sabka Vishwas (Legacy Dispute Resolution) Scheme follow-through
- Equalisation Levy assessments and appeals
- Transfer Pricing Officer (TPO) references + DRP objections
- Mutual Agreement Procedure (MAP) for cross-border tax disputes
- Advance Pricing Agreements (APA) — bilateral and unilateral
- GAAR and SAAR enquiries before the Approving Panel
- Penalty under Sections 270A, 271(1)(c), 271AAB, 271D / 271E
- Section 263 revision proceedings by the PCIT
- Section 264 revision applications by the assessee
- Stay applications before the AO, CIT(A), ITAT, High Court
- Show-cause notice replies under Section 25 of Customs Act
- Anti-dumping and safeguard duty disputes before DGTR
- SEBI investigation and adjudication proceedings
- Income Tax prosecution under Sections 276B / 276C / 276CC
- Benami transactions — Initiating Officer notices and Tribunal
- Black Money Act (Undisclosed Foreign Income and Assets) defence
- Trade-mark and copyright disputes — IPAB and High Court IP Division
- Consumer Forum representation for service-deficiency claims
- CCI (Competition Commission) anti-trust and merger control notices
- Real Estate (Regulation and Development) — RERA disputes
- Departmental Promotion Committee (DPC) and disciplinary proceedings
Don\u2019t see your specific need? Send us a brief description in writing — we will honestly tell you within 24 hours whether we are the right team for it.
A five-step engagement, designed for clarity.
Every engagement at Zfiling runs through the same disciplined workflow.
Triage
Within 24 hours of the notice — read it, classify the section, check the statutory timeline, identify whether to respond or seek an adjournment. No fact-finding yet, just calendar and strategy.
Investigate
Pull the contracts, ledgers, returns, board resolutions, communications. Build a fact matrix. Map every claim in the notice to documentary evidence. Identify weak points honestly.
Draft
Reply prepared with senior partner review, case law indexed, ratio extracted and applied. Annexures organised. Pre-deposit and stay strategy worked out before submission.
Represent
Personal hearings, video conferences, oral arguments — handled by the partner who drafted the reply. No outsourcing to junior associates who have not read the file.
Follow-through
Order analysed within 48 hours of receipt. Appeal, rectification or compliance, as warranted. The matter is not closed until the file is.
Four ways to work with us.
Fixed-fee for one-off engagements. Scaled by complexity or turnover. Monthly retainer for ongoing engagements.
Per-notice fee depending on quantum of demand and complexity. Includes one personal-hearing representation. Most replies fall within a predictable band.
Filed, drafted, paper-book prepared, oral hearings attended through to order. Quoted on case complexity and demand quantum. Pre-deposit assistance included.
Filing and drafting at stage rate. Oral hearings at per-hearing rate. Bundled rates available for multi-year batch matters. Senior counsel briefed only where strategically required.
For clients with continuous notices — single point of accountability, monthly status reports, predictable budget. Tribunals, writs and prosecution defended at agreed slab rates.
Should I respond to the notice myself or use a professional?
The first response sets the tone, identifies the issues, and creates a record. Self-drafted replies often contain admissions that come back to haunt the matter two years later at the tribunal. For any notice involving a tax demand, a penalty proposal or a request for personal appearance, the cost of professional drafting at the start is a small fraction of the cost of unwinding a bad record at the appellate stage.How long does a faceless assessment appeal at the CIT(A) take?
Currently, between nine and eighteen months from filing Form 35 to disposal — the National Faceless Appeal Centre clears matters by jurisdictional batches. Hearings are typically through written submissions and video conferences. We seek expedited listing where the demand is large or hardship is demonstrable. The ITAT timelines are generally faster — six to twelve months for first hearing.Do I have to deposit anything before filing an income-tax appeal?
There is no statutory pre-deposit for the first appeal before the CIT(A). However, where a stay of demand is not granted, the AO can initiate recovery (under Section 220) — so most appellants either obtain a stay or make a part-payment (typically 20% of the demand under the CBDT instruction) while the appeal is pending. For GST appeals before the Commissioner (Appeals), there is a statutory 10% pre-deposit; for the (proposed) GSTAT, an additional 20%.Can I retract a statement made during a search or survey?
Legally yes, factually difficult. A statement recorded under oath under Section 132(4) (search) or Section 133A (survey) is admissible as evidence — retraction requires immediate written objection citing duress or factual error, with corroborative material. Late retractions are usually discounted by assessing officers and tribunals. We routinely structure post-search retractions where the original statement is clearly incorrect, but the strategy depends heavily on facts and timing.What is the difference between Section 73 and Section 74 of the CGST Act?
Section 73 covers cases where the demand arises without fraud, wilful misstatement or suppression of facts — the time limit is three years from the due date of the annual return and the penalty is restricted (often capped or waived if dues are paid early). Section 74 covers fraud / suppression cases — the time limit is five years and the penalty is 100% of the tax. The single largest litigation issue at the SCN stage is to argue down a Section 74 SCN to Section 73 — it materially changes the penalty exposure.Are EPF demands appealable, and where?
Yes. Orders under Section 7A and Section 7Q / 14B of the EPF Act are appealable before the Employees Provident Fund Appellate Tribunal (EPFAT) within 60 days of the order. The pre-deposit for filing is generally 75% of the dues for non-employer demands; the tribunal can waive or reduce this for hardship. Second appeal is to the High Court and then the Supreme Court. ESI orders have a parallel structure before the Employees Insurance Court (a designated civil court).Can a tax dispute be settled outside the formal appeal route?
Sometimes. The Direct Tax Vivad se Vishwas Scheme (when notified) allows resolution of pending direct-tax disputes at fixed percentages of the disputed demand. Section 273A and 273AA of the Income Tax Act permit reduction or waiver of penalty by the PCIT in specified situations. GST has its own Amnesty Schemes that are notified periodically. We monitor and apply these strategically — but the case law route remains the principal channel.What is a writ petition and when does it apply?
A writ is an extraordinary remedy under Article 226 (High Court) or Article 32 (Supreme Court) — typically used where (a) there is no alternative remedy, (b) the alternative remedy is illusory, (c) there is a fundamental rights violation, (d) the order is without jurisdiction, (e) there is denial of natural justice. Writs bypass the appellate hierarchy but are entertained sparingly. We use them strategically — for stay during recovery, for quashing of jurisdictionally infirm notices, and for matters where speed is essential.Do you handle cross-border tax disputes?
Yes — through Mutual Agreement Procedure (MAP) under DTAAs, bilateral Advance Pricing Agreements (APAs), withholding-tax disputes for foreign payments, royalty and FTS characterisations, PE attribution disputes and disputes over treaty benefits. The Indian Competent Authority is the JS (FT&TR) at the CBDT. We coordinate with overseas advisors where the matter is bilateral.How is your fee structured for litigation matters?
For notice replies and adjudications, a fixed fee per matter. For appeals, a stage fee (drafting + filing) plus a per-hearing fee for oral representation. For tribunal and writ matters, a senior partner-led retainer or per-matter scope. For clients on a continuous litigation calendar, an all-inclusive monthly retainer. Senior counsel where briefed are billed separately at agreed rates. We do not work on contingency for tax matters.Can you defend criminal prosecution under tax laws?
Yes. Income tax has prosecution provisions under Sections 276B (TDS non-payment), 276C (wilful evasion), 276CC (failure to file return) and others. The Customs Act has parallel provisions; the CGST Act has Section 132 prosecution. The Black Money Act and PMLA add complications. We defend at the magistrate stage and brief criminal-side senior counsel for sessions and High Court proceedings, working in tandem with the tax-side strategy.What is your success rate?
We don\u2019t publish a number because it would be meaningless without context — outcomes depend on facts, evidence quality and the stage at which we are engaged. What we can commit to: in matters where we are engaged at the notice stage (rather than rescuing a botched first response), the majority resolve at the CIT(A) / Commissioner (Appeals) level without going to tribunal. Most tribunal matters that we accept have a defensible legal position before we agree to file.
A notice on your desk? Send it to us today.
The first 30-minute consultation is on us. A senior advisor responds within one business day.
+91 8338 981 953 · infoZfiling@gmail.com
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