Direct Tax

Compliance, representation and planning under the Income-tax Act, 2025, including the IFSC unit deduction under s.147 and the concessional rate under s.218.

Direct Tax
Scope of work

Compliance, representation and planning under the Income-tax Act, 2025, in force from 1 April 2026 - including the IFSC deduction that now sits at s.147.

Compliance

  • Return of income under s.263 - original, belated, revised and updated
  • Tax audit under s.63, reported in Form 26
  • Withholding tax under s.392 and s.393
  • Lower or nil deduction certificates under s.395(1) in Form 128

Representation

  • Assessment and appellate representation before the Commissioner (Appeals)
  • Appellate Tribunal representation under s.362
  • Advance rulings before the Board for Advance Rulings
  • TDS default and penalty exposure under s.398 and s.448

IFSC planning

  • IFSC unit deduction under s.147 - 100% of business income for 20 of 25 years
  • Concessional 15% rate on IFSC and offshore banking unit income under s.218
  • IFSC exemptions under s.11(1) read with Schedule VI
  • Fund manager safe harbour under s.9(12) read with Schedule I

Mind the renumbering: s.147 was s.80LA · Schedule VI was s.10(4D) to s.10(4H) · s.263 was s.139 · s.63 was s.44AB. New s.147 is the IFSC deduction, while income escaping assessment has moved to s.279.