Service
Transfer Pricing Litigation & Dispute Support
At AventaaGlobal, we support businesses in preventing, managing, and resolving transfer pricing disputes in a timely and structured manner. Our focus is to protect your position, ensure procedural compliance, and present your case with clarity—supported by strong technical analysis and well-prepared evidence.
We support dispute matters across jurisdictions. Where a forum or process is country-specific (for example, Indian appellate forums), we mention it explicitly.
Our Services
Support across the full dispute lifecycle—from dispute prevention to resolution.
Representation & Advocacy (India-Specific Forums)
Representation before the Transfer Pricing Officer (TPO)
We represent clients before the TPO, defending the transfer pricing position through clear fact framing, robust technical analysis, and well-structured submissions.
Income Tax Appellate Tribunal (ITAT) and Higher Forums
We support complex matters at the ITAT level and coordinate litigation strategy for further appellate stages as required.
Commissioner of Income Tax (Appeals) [CIT(A)]
We provide end-to-end support for appellate proceedings before the CIT(A), including drafting of grounds of appeal, preparation of written submissions, and development of a coherent argument strategy.
Submissions, Appeals & Correspondence
We meticulously prepare submissions, objections, appeals, and correspondence to tax and appellate authorities to ensure the case is presented consistently, accurately, and with strong supporting evidence.
Dispute Resolution Panel (DRP)
We assist in DRP matters by preparing persuasive objections, supporting evidence packs, and structured representations aligned with procedural and technical expectations.
Support to Senior Counsel (High Courts / Supreme Court)
Where matters escalate, we provide comprehensive technical briefings and documentation support to external counsel, ensuring they have complete, coherent, and well-referenced materials to argue the case effectively.
Dispute Prevention, Controversy Management & Defence Strategy (Multi-Jurisdiction)
Dispute Readiness and Defence File Preparation
We help build a structured defence file covering key facts, transaction narratives, economic rationale, and evidence mapping—so responses are faster, consistent, and audit-ready.
Risk Review and Issue Identification
We identify high-risk transactions, recurring adjustment themes, and common challenge areas, and recommend targeted mitigation steps to reduce the likelihood of disputes.
Response Support for Information Requests and Assessments
We support the preparation of responses to tax authority queries, including fact gathering, narrative alignment, and presentation of technical positions in a clear and defensible manner.
Simultaneous Examination / Joint Audit Coordination
We support end-to-end coordination during multi-jurisdiction audits or simultaneous examinations—aligning fact patterns, maintaining narrative consistency, and managing cross-country information flows to reduce duplication and double-tax risk.
Penalty Defence and Procedural Strategy
We support penalty risk assessment and defence strategy during proceedings, with a focus on procedural robustness, coherent evidence, and consistent positions to reduce exposure and strengthen outcomes.
Dispute Resolution Mechanisms (Domestic and Cross-Border)
Advance Pricing Agreements (APA)
We assist throughout the APA lifecycle—from feasibility assessment and application to documentation support and negotiation—helping establish certainty and manage transfer pricing risk effectively.
Mutual Agreement Procedure (MAP)
We guide clients through MAP proceedings to resolve cross-border disputes between tax authorities, to eliminate double taxation and achieve a balanced outcome.
ICAP Support (International Compliance Assurance Programme)
We assist multinational groups in preparing and managing ICAP engagements—structuring the information package, aligning positions across jurisdictions, and coordinating responses to support early multilateral tax risk comfort.
Safe Harbour Applications (Where Applicable)
Where jurisdictions provide safe harbour options, we support evaluation, documentation coordination, and filing requirements to streamline compliance and reduce litigation exposure.
Corresponding Adjustment and Secondary Adjustment Support
We support analysis and resolution strategies for corresponding adjustments and secondary adjustment implications, to reduce double taxation and align outcomes across jurisdictions and processes.
India-Specific Add-on Support (Where Applicable)
Multi-year / Block TP Assessment Strategy (India)
Where multi-year or block assessment approaches apply, we support strategy and submission architecture across covered years, helping ensure consistency of facts, evidence, and positions.
Outcome
Our objective is to help you resolve disputes efficiently and defensibly—through strong technical positions, disciplined process management, and clear advocacy—so your leadership team can stay focused on business priorities.