Harun Raaj & AssociatesHarun Raaj & Associates
Indirect Tax Services

Indirect Tax Advisory

Indirect Tax Advisory

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Overview

Indirect tax advisory is the strategic review and the ongoing management of a business's indirect tax — the GST under the CGST Act 2017, the customs under the Customs Act 1962, and the export and the trade incentives under the Foreign Trade Policy. The advisory covers the classification and the rate positions, the input tax credit and the refunds, the compliance and the assessments, and the notices — with the same statute-backed rigour across each. It is the service a business engages when its indirect tax has grown beyond the monthly filings.

The indirect tax structure is where a business's margins are quietly decided. The classification of a product, the credit claimed on an input, the incentive claimed on an export — each moves the effective tax rate, and each is a position the department will test. The advisory keeps the positions documented and current, so the business knows its effective rate and can defend it.

The cost of the unmanaged structure is the surprise: the notice that arrives with a demand the business never saw coming, the refund that was never claimed, the incentive that was never structured. Each surprise is a position that would have been cheaper to manage than to defend.

This service is for businesses with a meaningful indirect tax footprint. We review the GST, the customs and the incentive positions under the Acts, identify the savings and the exposures, document the positions for the audit, manage the compliance and the refunds, and respond to the notices — so the indirect tax is a managed position rather than a series of surprises.

How It Works

  1. 1

    Indirect Tax Review

    We review the GST, the customs and the incentive positions of the business.

    Harun Raaj & Associates does this1-2 weeks
  2. 2

    Savings & Exposure Identification

    We identify the savings, the refunds and the exposure positions.

    Harun Raaj & Associates does this1 week
  3. 3

    Position Documentation

    We document the positions with the statute and the record support.

    Harun Raaj & Associates does this1 week
  4. 4

    Compliance & Refund Management

    We run the compliance and the refund claims on the identified positions.

    Harun Raaj & Associates does thisOngoing
  5. 5

    Notice & Audit Support

    We respond to the notices and the audits on the indirect tax positions.

    Harun Raaj & Associates does thisAs required

Frequently Asked Questions

What types of indirect tax advisory does a CA firm provide?
Advisory covers: (a) GST rate and classification opinions — HSN/SAC classification letters with statutory analysis; (b) pre-transaction structuring — supply chain, composite/mixed supply analysis, and place of supply planning; (c) ITC optimisation — mapping blocked credits, Rule 42 reversal minimisation, ISD structure; (d) customs duty planning — FTA utilisation, SVB pricing, advance ruling applications; (e) FTP benefit structuring — AA, EPCG, RoDTEP eligibility; (f) Advance Pricing Agreement and Advance Rulings.
When is a pre-transaction indirect tax opinion critical?
Before: launching a new product or service (rate uncertainty); entering a new state (registration obligation, place of supply); making a large capital goods import (BCD, SWS, IGST implications); signing a multi-element contract (composite vs. mixed supply analysis); claiming a FTP benefit (AA, EPCG — wrong usage nullifies the licence); or an M&A transaction (ITC position, IGST on slump sale vs. itemised asset sale). After the transaction, changing the tax treatment creates amendment/reversal risks.
How does indirect tax litigation advisory work?
Litigation advisory covers: (a) drafting reply to show cause notices under Section 73/74 CGST Act or Section 28 Customs Act; (b) representation before the Adjudicating Authority, Commissioner (Appeals), CESTAT (for pre-GST excise/service tax), and GSTAT (when operational); (c) High Court/Supreme Court — briefing counsel on indirect tax matters; (d) advance rulings at AAR/AAAR; (e) settlement commission applications (for pre-GST matters under SVLDRS). The CA prepares the factual and legal matrix; the advocate argues.
What is the SVLDRS and is it still available?
Sabka Vishwas Legacy Dispute Resolution Scheme 2019 (SVLDRS) was a one-time settlement window for pre-GST disputes (excise, service tax, customs duties) — closed 30 June 2020. Disputes that were not settled under SVLDRS continue before CESTAT, High Courts, and the Supreme Court. For pre-GST matters (FY 2000–2017) still pending, conventional litigation is the only route. New disputes under GST law go through the Section 107/112 appeal structure and eventually GSTAT/High Court.
What is the role of a CA in an indirect tax due diligence?
In M&A indirect tax DD: (a) review GST return filing history and GSTR-9/9C for last 3 years for material reconciliation differences; (b) check open notices (GSTN portal — notices visible to registered taxpayers); (c) verify ITC position — any Section 73/74 demand, GSTR-2B mismatch, or Section 16(4) time-barred credit taken; (d) check customs import history for SVB-related party pricing alerts, EPCG/AA export obligation status; (e) quantify contingent indirect tax liability and include in deal terms (escrow or price reduction).

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