Direct Tax Litigation · Ahmedabad
The assessment is over.
The argument begins.
Sunil Maloo & Co. is a litigation-first chartered accountancy practice. Our work concentrates on direct tax matters that have outgrown compliance — search and seizure assessments, on-money and real estate additions, reassessment under section 148, and the appellate record that has to carry them through the CIT(A) and the Tribunal.
For referring chartered accountants & advocates
Where a second set of hands earns its place.
Professionals bring us into a file when the matter turns evidentiary rather than arithmetical — when the addition rests on a seized document, a statement recorded under oath, or an estimate the Assessing Officer has not troubled to reconcile. We work alongside the existing advisor, not around them.
Sections 132 · 153A · 153C
Search & Seizure Assessments
Post-search assessments turn on what the seized material actually proves. Loose papers and dumb documents, statements recorded under section 132(4) and their retraction, the right to cross-examination, and the jurisdictional foundation of a section 153C satisfaction note.
The search practiceDevelopers · Builders · Land
Real Estate Tax Litigation
On-money additions, rejection of books under section 145(3), percentage-of-completion disputes, section 43CA and 56(2)(x) valuation differences, unsecured loans and capital introduction, and the quantum reconciliation that follows a blanket estimate.
Real estate disputesCIT(A) · ITAT · Faceless
Appellate Practice
Grounds drafted to be argued, not merely filed. Statements of fact, applications for admission of additional grounds under section 250(5), written submissions built on a document-anchored record, and paper books assembled so the bench can find what matters.
Appellate workIf a notice has already reached you
Start with what is in your hand.
Most of what determines the outcome of a tax dispute happens early — in what is said in reply, what is placed on record, and what is allowed to go unchallenged. Find the provision on your notice below.
Time limits do not wait for a decision.
Appeals, objections and replies each run on their own clock, and several of them are measured in days rather than months. If a limitation date is approaching, say so when you write — it changes the order in which things need to be done.
How a matter runs
The record decides the appeal.
An appellate authority cannot act on an argument that has no foundation in the file. Most of the work in a tax dispute is therefore not advocacy — it is building a record that makes the argument unavoidable.
An addition sustained on an estimate is only as strong as the material the estimate was drawn from.
Practice noteRead the order against the record
The assessment order, the seized material it relies on, the statements, the show-cause and the reply are read together. What the order asserts and what the record actually supports are rarely the same document.
Separate the jurisdictional from the merits
Whether the assessment could lawfully be made at all — satisfaction, approval, limitation, service, the existence of incriminating material — is a distinct enquiry from whether the addition is right. Both are taken, in that order.
Reconcile the quantum, line by line
A blanket estimate is met with a reconciliation: what is already recorded in the books, what is duplicated across years, what pertains to another entity, and what survives. A number the Department cannot break is worth more than an argument it can.
Draft to be argued
Grounds, statement of facts and written submissions are drafted as a single structure, each ground tied to a contention and each contention anchored to an enclosure. Where a ground was missed at filing, it is brought in properly under section 250(5) rather than argued without foundation.
Insights
Published analysis.
Reading of statute, judgments and Finance Act amendments as they land — written for practitioners, in long form and in slides.
Brief us
Bring us the order and the record. We will tell you what it is worth.
An initial reading tells you where the matter stands, which grounds are worth taking, and what the record still needs. Send the assessment order and the notice, and we will respond with a view.