Aanjul D.

Tax Advocate at Chambers of Mr. Salil Kapoor, New Delhi

Worked on high-stakes direct tax litigation across Supreme Court, High Court, and ITAT, with focus on reassessment and faceless assessment challenges, search and seizure matters, and transfer pricing disputes. Drafted and finalized writ petitions and appellate submissions addressing limitation/procedural ultra vires/natural justice grounds under relevant provisions of the Income Tax Act. Supported appellate strategy in reported/landmark matters including reassessment time-bar issues and jurisdictional defects. Also handled advisories for large corporate clients covering refunds, stay of demands, consequential relief implementation, and rectification under Section 154. Conducted technical research for GAAR/POEM/PE and treaty interpretation issues and prepared restructuring analyses for GST/TDS implications in business model transitions.

Intern - Direct & International Tax at Shreya Rao & Associates, Bengaluru

Assisted in direct/domestic and international tax research and drafting involving reassessment/faceless assessment proceedings, search and seizure litigation, writ petitions before High Courts/SC, ITAT appeals, stay of demand, penalty proceedings, and deductions/capital gains issues. Supported GST refund/input credit/classification/valuation research and researched Equalisation Levy applicability and India/DTAA interpretation topics. Worked on procedural safeguards for cross-border reassessment and contributed to a memorandum relating to establishing aircraft leasing subsidiaries in GIFT City IFSC with PE and withholding tax/treaty considerations.

Intern - Tax Practice at Al Tamimi & Company, Dubai

Reviewed UAE VAT refund claims for construction clients and verified input tax recovery eligibility under relevant UAE Federal Decree-Law and FTA regulations. Researched UAE Economic Substance compliance and exposure for multinationals across free zone/mainland contexts. Developed tax memoranda for a Saudi Arabian family office regarding UAE Corporate Tax implications for investment holding structures and cross-border income streams.

Intern - Tax Practice at Shardul Amarchand Mangaldas & Co., Mumbai

Researched Equalisation Levy exposure in connection with gaming cross-border digital transactions, distinguishing it from income tax/PE provisions and identifying mitigation strategies. Evaluated DTAA treaty clause implications for withholding rates under applicable treaty contexts and researched admissibility of evidence from tax raid/survey material. Analyzed TDS obligations under Section 194C for reimbursements and composite service arrangements and assessed compliance/disallowance risks.