Transfer Pricing & Int'l Tax

Comprehensive cross-border controversy masterclass before ITAT Ahmedabad Benches: Challenging TPO benchmarking filters, establishing negative working capital adjustments, capping corporate guarantee fees at 0.5% under Gujarat HC precedents, and prosecuting DRP objections by PGT & Associates.

Authoritative cross-border wealth repatriation manual for Non-Resident Indians: Liquidating Indian property and equity investments, satisfying AD-1 bank scrutiny, navigating Form 15CA Part C and Form 15CB CA certification, and FEMA USD 1 Million limits by PGT & Associates.

Rule 10DA ties AY 2026–27 Form 3CEAA Master File filing to the applicable Section 139(1) return due date. Section 92E cases generally have a 30 November 2026 return date; the ordinary audited-return category was extended to 21 November 2026.

Cross-border tax guide for US-based Indian diaspora: Mitigating punitive Passive Foreign Investment Company (PFIC) rates on Indian mutual funds, filing Form 67 for Foreign Tax Credit (FTC), and claiming DTAA Article 25 relief by PGT & Associates.

Master guide for returning Indian diaspora: Leveraging Resident but Not Ordinarily Resident (RNOR) status for 2-3 tax-free transition years, re-designating NRE/NRO accounts under FEMA, and navigating mandatory foreign asset reporting in Schedule FA by PGT & Associates.

Step-by-step cross-border real estate taxation manual for NRIs: Eliminating standard 20% to 30% TDS under Section 195 via Form 13 Lower Deduction Certificate, buyer TAN requirements, Section 54/54EC exemptions, and repatriating sale proceeds via Form 15CA/15CB by PGT & Associates.

Authoritative cross-border regulatory guide for businesses and NRIs in Dubai (UAE) and Singapore: Mandatory Indian CA certificates under FEMA, Form 15CB/146 outward remittances, Transfer Pricing Form 3CEB, FDI valuation (FC-GPR/FC-TRS), and lower TDS Form 13 compliance by PGT & Associates.

Authoritative banking and international tax masterclass for Non-Resident Indians: FEMA Schedule 3 repatriation rules, tax-free NRE/FCNR interest vs taxable NRO income, converting resident savings accounts upon NRI status change, and Form 15CA/15CB remittance procedures by PGT & Associates.

Cross-border estate masterclass for Non-Resident Indians: FEMA Section 6(5) rights on inherited agricultural and urban property, court probate vs legal heirship, zero inheritance tax under Section 56(2)(x), Section 195 withholding, and USD 1 Million repatriation via Form 15CA/15CB by PGT & Associates.

Authoritative legal and cross-border tax masterclass for Non-Resident Indians: Power of Attorney (PoA) execution abroad, Indian consulate attestation, state stamp duty adjudication, Form 13 Section 195 lower TDS certificates, and Form 15CA/15CB sale proceeds repatriation by PGT & Associates.

Operational guide for overseas investors: FEMA Schedule 1 repatriable vs Schedule 4 non-repatriable routes, Portfolio Investment Scheme (PIS) bank accounts, and capital gains tax withholding under Section 195 by PGT & Associates.

International tax manual on treaty override principles: Section 90(2) supremacy over Section 206AA, TRC and Form 10F documentation, and landmark judicial rulings on non-resident withholding by PGT & Associates.

Authoritative cross-border tax masterclass for US-based NRIs: Avoiding punitive PFIC tax rates on Indian mutual funds, Section 89A deferred taxation on 401(k)/IRA accounts, and Form 67 foreign tax credit claiming by PGT & Associates.

Complete transition manual for NRIs relocating to India: RNOR 2-to-3 year tax holiday, FEMA Section 6(4) foreign asset retention, Resident Foreign Currency (RFC) accounts, and Schedule FA Black Money Act compliance by PGT & Associates.

Comprehensive cross-border tax manual for NRIs selling property in India: Section 195 TDS mitigation, Form 13 Lower Deduction Certificate, Section 54/54F capital gains exemptions, and Form 15CA/15CB banking repatriation by PGT & Associates.

Litigation roadmap comparing DRP under Section 144C vs CIT(Appeals): 30-day filing in Form 35A, statutory 9-month adjudication limit, TPO adjustment defense, and ITAT direct appeal by PGT & Associates.

Corporate international tax manual on cross-border SaaS, cloud hosting, and digital advertising: Post-equalisation levy transition, Section 195 withholding triggers, treaty benefits, and Form 15CA/15CB protocols by PGT & Associates.

Operational guide on cross-border outward remittances under Rule 37BB: Determining applicability across Parts A, B, C, and D of Form 15CA, Form 15CB CA certification requirements, and Authorized Dealer bank compliance by PGT & Associates.

Strategic transfer pricing advisory on intra-group shared IT infrastructure and software cost recharges: OECD Cost Contribution Arrangement principles, allocation keys, markup scrutiny, and Form 3CEB reporting by PGT & Associates.

Exhaustive legal guide on claiming Foreign Tax Credit (FTC) in India: Rule 128 statutory requirements, Form 67 filing deadlines post-amendment, DTAA credit caps, and ITAT relief on procedural delays by PGT & Associates.