India

7th Floor, Building 10

Tower B DLF Cyber City Complex

DLF City Phase II

Gurgaon – 122 022, Haryana

India

Tel: +91 124 679 2901

Email: rajivanand@deloitte.com

Website: www.deloitte.com

Rajiv Anand is a corporate tax partner in the global business tax practice of Deloitte Haskins & Sells, India. He has more than 23 years of experience in domestic and international corporate taxation matters including cross-border restructurings, legal interpretations, in-depth analysis and strategic planning and advisory support to clients. Rajiv has significant experience dealing with various domestic and international organisations in relation to handling and assisting in their assessments and appellate matters up to the courts.

The core areas of Rajiv's experience include due diligences and international tax restructurings; in-depth analysis and strategic planning for inbound investments, keeping in view the taxation regime, double taxation avoidance agreements and exchange control regulations connected with complex cross-border transactions; advising clients on various regulatory and tax aspects of corporations doing business with or in India; dealing with various domestic and international multinationals in relation to handling their assessments and appellate proceedings all the way up to the courts. He is instrumental in assisting companies in obtaining landmark decisions from courts on matters where there were no legal precedents.

Rajiv's experience also includes analysing the constitutional validity of retrospective amendments and advising clients on the same, analysing the recently introduced general anti-avoidance rules (GAAR) in light of international rulings and principles and advising various clients, and day-to-day advisory and compliance support to multinational clients.

Rajiv is a member of the Institute of Chartered Accountants of India (ICAI) and the Institute of Cost and Works Accountants of India (ICWAI).

Maruthi Infotech Centre, 11/1 and 12/1 East Wing, II Floor,

Bangalore, Karnataka, 560 071

India

Tel: +91 80 3980 6700

Email: krgirish@kpmg.com

Website: www.kpmg.com/in

K R Girish is a senior partner in the firm's tax and regulatory services group, and is head of the tax dispute resolution practice at B S R & Co – KPMG in India.

K R has more than 30 years of experience in the tax and regulatory area and has done substantial work in the tax advisory and compliance areas. He also has extensive experience advising on transfer pricing and related issues. He represents clients before tax authorities at various forums and regularly appears before the tax commissioners and the tax tribunal on complex tax issues.

KR is actively involved with the Chambers of Commerce and has worked on various policy initiatives with the government. He is a member of The Confederation of Indian Industries (CII) southern region committee for economic affairs.

He was previously a president of The Bangalore Chamber of Commerce and Industry (BCIC) and continues to be a member of the Chamber's steering committee.

KR is also a member of the Federation of Indian Chambers of Commerce and Industry's (FICCI) taxation committee, Bengaluru and the co-member of the Committee on International Taxation of The Institute of Chartered Accountants of India (ICAI) for 2014-2015.

He is a fellow member of ICAI and an associate member of the Australian Taxation Institute. He holds a postgraduate diploma in taxation practice from MS University, Baroda.

Indiabulls Finance Centre

Tower 3, 27th-32nd Floor,

Senapati Bapat Marg, Elphinstone Road (W)

Mumbai, Maharashtra 400013

India

Tel: +91 22 6185 4288

Email: manishagupta@deloitte.com

Website: www.deloitte.com

Manisha Gupta is a partner in Deloitte Haskins & Sells' transfer pricing practice. She has more than 15 years of experience in the fields of transfer pricing and international tax and has anchored some key transfer pricing litigation in India.

Since joining Deloitte India, Manisha has assisted leading Indian and foreign multinational companies to manage and resolve contentious transfer pricing controversy issues. She has also conducted a number of transfer pricing projects in a variety of industries (such as pharmaceutical, infrastructure, FMCG, software and ITeS, hospitality, logistics and more) involving audit defence, mutual agreement procedures (MAP), advance pricing agreements (APAs) as well as planning and documentation studies. These have addressed a wide range of transfer pricing issues such as financial transactions including guarantees, intangibles, and characterisation.

Manisha is a frequent speaker on transfer pricing topics and has authored and coauthored various articles on transfer pricing controversies, alternate dispute resolution, and so on. She is a member of the Institute of Chartered Accountants of India and has previously worked with Ernst & Young and KPMG.

PwC House, 3rd Floor

Guru Nanak Road

Bandra West, Mumbai – 400 050

India

Tel: +91 22 6689 1377 (Mumbai); +91 124 3306512 (Delhi)

Fax: +91 22 6689 1888 (Mumbai); +91 11 330 6999 (Delhi)

Email: kanchun.kaushal@in.pwc.com

Website: pwc.com/taxcontroversy

Kanchun provides litigation support and insights for defence strategies for ITAT matters

Kanchun Kaushal is an executive director in the tax and regulatory services group based out of Mumbai and Delhi. He plays a pivotal part in PwC's litigation practice in India. He joined PwC in March 2009 along with his enriched experience of almost 20 years in this field. Before joining PwC, he had a very well established practice of his own and was one of the leading counsels of the northern region of India. He has a bachelor's degree in commerce from the Delhi University and qualified as a chartered accountant in 1987. He is a fellow-member of the Institute of Chartered Accountants of India and also a member of the Income Tax Appellate Tribunal Bar Association.

• He has a versatile tax litigation experience combined with apt knowledge of accounting and corporate laws.

• He has handled issues across a spectrum of direct tax and regulatory areas, enveloping sectors including oil & gas, energy, service providers, media, IT, pharma, shipping, automative, and banking.

• Apart from this, he has advised several large Indian and multinational corporate individuals/groups, government undertakings on various aspects of domestic and cross-border taxation and tax treaty interpretation.

• He has argued more than 3000 cases before various appellate authorities and several of his cases have been reported in various journals issued by different publication houses.

• In his stint at PwC for the past five years, he has argued more than 600 cases with a 98% success ratio on issues involving corporate tax, international tax and transfer pricing

• Handling the litigation tax practice starting from the primary level up to the levels of appellate authorities including the Dispute Resolution Panel, the Authority for Advance Rulings (AAR), mutual agreement procedure (MAP) and so on.

• First favourable tribunal judgment on the issue of interpretation of the word 'charter' as appearing in Article 8 in a non-OECD model treaty;

• First favourable advance ruling on India-Mauritius treaty post-Bombay High Court decision in the Aditya Birla Nuvo case;

• First favourable tribunal judgment on service PE;

• First favourable tribunal judgment on software royalty considering contrary High Court decisions;

• First favourable tribunal judgment on valuation of shares between two associated enterprises;

• First favourable tribunal judgment on penalty for transfer pricing adjustment.

PricewaterhouseCoopers Private Limited

Building No 10, 17th Floor

Tower C, DLF Cyber City

Gurgaon ,122 002

India

Tel: +91 124 3306517

Fax: +91 124 3306999

Mobile: +91 9810156190

Email: pawan.kumar@in.pwc.com

Website: pwc.com/taxcontroversy

Pawan Kumar is the executive director of PwC's tax & regulatory services practice. With an extensive experience of more than 35 years as a tax legal adviser, Pawan advises a wide range of clients from different industries on their tax position. Based on the tax position review, he recommends strategies including overall compliance of tax obligations, reducing exposure risk.

Pawan possesses an in-depth knowledge of direct tax laws with an active practice of tax advocacy before different forums.

With the skills acquired over years of practice, Pawan is adept in managing complex tax controversies, drafting petitions and representing clients before various tax authorities and courts of law. He helps clients achieve effective litigation strategies in their tax matters before various courts, helps the client understand the legal position and the court related practice and procedures for the effective hearing of their matter. He advises clients on conceptualising tax effective alternatives and plans, evaluation and minimisation of tax exposure in business transactions.

He has been one of the forerunners in the litigation of cross-border transactions involving the interpretation of tax treaties and their interplay with the domestic law including allied transfer pricing litigation. He also has vast experience in advising clients on various international tax issues such as the taxability of EPC contracts involving offshore supplies, the existence of permanent establishments and allied attribution related issues, taxation of FTS/royalty and so on, as well as drafting and presenting legal averments on such issues before various appellate/dispute resolution authorities such as the Authority for Advance Rulings and Income Tax Appellate Tribunals across India. He has been working closely with some of the legal luminaries of India. Pawan is a fellow member of the Institute of Chartered Accountants of India (ICAI). He also holds a graduate degree in law. He is a first rank holder in the master's programme of tax management, a post-qualification tax specialisation from ICAI.

Building No 10, Tower C

17th Floor, DLF Cyber City, Gurgaon

Haryana – 122 002

India

Direct: +91 124 330 6501

Fax: +91 124 330 6999

Mobile: +91 98300 55281

Email: rahul.k.mitra@in.pwc.com

Website: pwc.com/taxcontroversy

Rahul Mitra is a partner in the transfer pricing practice of PwC India. Rahul was the national leader of PwC India's transfer pricing practice between 2010 and 2014. Rahul is a chartered accountant and an honours graduate in commerce. Rahul has been a partner in the tax & regulatory services practice of PwC India since 1999.

Rahul has more than 20 years of experience in handling tax and regulatory matters in India. He specialises in transfer pricing, particularly inbound & outbound planning assignments; advice on profit/cash repatriation planning; value chain transformation or supply chain management projects; and profit attribution to permanent establishments.

Rahul independently handles litigation for top companies at the level of the income tax tribunals. At least 40 of the cases argued by Rahul have been reported in leading tax journals of India. Some of the major wins of Rahul before tax tribunals in transfer pricing matters have been precedent-setting cases, both in India and globally:

• BMW India – marketing intangibles in the case of distributors, distinguishing ruling of Special Bench of Tribunal in the case of LG Electronics;

• GAP India – remuneration model for procurement services company, addressing issues of 'Berry ratio' and location savings;

• Global One India – accepting residual profit split method and distinguishing it from comparable profit split method, being covered by Income Tax rules; also holding 'sixth method' to have retrospective operation;

• Schefenacker Motherson – concept of cash profit to sales as profit level indicator;

• Cheil Communications – concept of pass-through cost for intermediary companies;

• Development Consultants – concept of tested party, as least complex of two transacting entities; foreign related parties accepted as tested parties for first time in India;

• Fulford India – concept of value added distributor for secondary manufacturers in pharmaceutical sector.

In his personal capacity, Rahul is presently handling several APAs in India, involving clients from across industries; and also covering complex transactions, including industrial franchise fees/variable royalties under non-integrated principal structures; contract R&D service provider model; distribution models, with related marketing intangible issues; financial transactions; and profit split models for royalties.

Rahul is a member of the editorial board of Transfer Pricing Forum, published by Bloomberg BNA. Rahul was the country reporter on the topic, 'Non-discrimination in international tax matters', for the 2008 IFA Congress held in Brussels. Rahul was invited by the OECD to speak at the 2012 Paris roundtable conference on developing country perspectives on APAs.

109 – A Wing

Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 22 6636 7000

Email: vikramnankani@elp-in.com

Vikram Nankani is a co-founder and partner at Economic Laws Practice, and heads the litigation and dispute resolution practice for the firm.

Vikram is an India-qualified lawyer, at the Bar since 1986. He completed his LLM from Government Law College, Mumbai, in 1988. Vikram has been the chairman of the indirect tax committee of the Indian Merchants' Chamber for the past two years and has also held the role of secretary of the Customs, Excise and Service Tax Bar Association, West Zone for the past six years. He was on the government tax panel for the State of Maharashtra. He is a committee member of All India Federation of Tax Practitioners (AIFTP). He is a fellow of the Chartered Institute of Arbitrators (CIArb), London and a director of its India branch. He is also a co-convenor of IPBA Dispute Resolution Committee. He is on the Panel of Arbitrators of the Singapore International Arbitration Centre (SIAC) and Kuala Lumpur Regional Centre for Arbitration (KLRCA).

Vikram has appeared as a counsel in LCIA, ICC, LMAA and KCIAB International Commercial Arbitrations and has also successfully represented the interest of several Indian and foreign clients in arbitrations under ICC, UNCTRAL, LCIA, LMAA GAFTA, SIAC, KCIAB, ICA and ad-hoc arbitrations.

Vikram is well known for his expertise in tax, particularly tax litigation matters. He has been recommended in the Tax Director's Handbook 2013. He has been ranked by Chambers Asia-Pacific for his expertise in tax consistently between 2011 and 2013 and for his expertise in dispute resolution by Chambers Asia-Pacific 2013 & 2014. He is also a 'highly recommended individual' in India by Asialaw Profiles 2014. The Asia-Pacific Legal500 2014 has mentioned him for his expertise in dispute resolution and he has also been identified in Who's Who Legal 2013 & 2014 as a leading practitioner in India for commercial litigation.

Deloitte Centre

Anchorage II

100/2, Richmond Road

Bangalore, Karnataka 560025

India

Tel: +91 80 6627 6105

Mobile: +91 98452 04631

Email: krsekar@deloitte.com

Website: www.deloitte.com

KR Sekar is a tax partner with Deloitte India and and co-leads the global business tax practice for Deloitte India. Sekar has more than 25 years of experience in the fields of direct taxes, mergers & acquisitions, international taxation and transfer pricing. His client portfolio includes leading companies in technology, media, telecommunications, manufacturing and engineering.

Sekar's key areas of expertise include inbound structuring, litigation support and advising on cross-border tax issues. He advises inbound global companies coming into India on entry strategy and inbound structuring, and assists them on mitigating tax risks. He is also associated with many landmark litigation cases for global companies.

In addition to advising clients, Sekar is active in representing before the government various tax issues impacting industry through his position in the Chambers of Commerce. He is also a prolific writer, contributing regularly to tax journals and newspapers. He has authored many books including Transfer Pricing Law & Practice, Taxation of Merger, De-merger & Foreign Collaboration and Landmark Judgements of Supreme Court on Direct Tax Laws: An Analysis.

Sekar is the chairman of the direct taxes expert committee of the Bangalore Chamber of Industry & Commerce, and is a member of the India Board of International Fiscal Association (IFA) and also works closely with other chambers including NASSCOM.

109 – A Wing

Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 22 6636 7000

Email: rohanshah@elp-in.com

Rohan Shah is the managing partner and leads the tax practice at Economic Laws Practice (ELP), a leading law firm in India.

Rohan received his law degree from the Government Law College of Mumbai University. After completing his LLB, he worked with Crawford Bayley and Co, Advocates and Solicitors, Mumbai (1988-1989). In 2001, Rohan founded ELP which currently has offices in Mumbai, Delhi, Pune, Ahmedabad, Bangalore and Chennai with a team in excess of 120 professionals.

Rohan is a qualified solicitor, and as a member of the Law Society of UK, is authorised to also practise in England & Wales. He is well known for his expertise in advisory, policy and controversy issues related to indirect taxes (excise, service tax, VAT and customs), domestic and international taxation in India. He is also actively engaged in various advisory and transactional issues in the areas of corporate and commercial transactions, media and international trade laws. As a litigator, Rohan has successfully represented a wide spectrum of clients before the Honourable Supreme Court, various high courts and tribunals resulting in several reported judgments in the areas of indirect tax and trade remedial disputes.

Rohan has been listed as a leading lawyer in India for his expertise in taxation and TMT practices by Asia Pacific Legal 500 and Chambers Asia-Pacific from 2009 to 2014; and by Asialaw Leading Lawyers 2013 & 2014. International Tax Review hailed him as being among the leading tax lawyers in the world, while Tax Directors Handbook recommended him from 2007 until 2013. He has also been selected among the 100 Leading Tax Lawyers in the World by Who's Who Legal – Corporate Tax 2009, Leading Lawyer by Who's Who Legal – Corporate Tax 2010 to 2014 and Trade & Customs 2013. He was also featured in Asian Legal Business' (ALB) Hot 100 in 2010 and India Today, January 2000 Edition as one of the '50 Indians for the Next Millennium'. He has recently been recognised as the exclusive winner of the corporate tax category in India in the Client Choice Awards 2014.

Indiabulls Finance Centre

28th Floor, Tower 3

Senapati Bapat Marg

Elphinstone Mill Compound

Elphinstone (W)

Mumbai – 400 013

India

Tel: +91 22 6619 8440

Fax: +91 22 6619 8401

Email: sunilshah@deloitte.com

Website: www.deloitte.com

Sunil is a tax partner with Deloitte India, based in Mumbai in the global business tax service line. Sunil also leads the Deloitte India tax centre of excellence, providing knowledge management and quality assurance services.

Sunil advises clients on various tax issues including tax planning, structuring of investments in India, contracts with foreign enterprises, expatriate taxation and on taxation of foreign enterprises in India.

Authoring several articles on tax matters, his views have frequently been carried by the print and electronic media. In addition, Sunil has presented at various seminars organised by professional and industrial organisations both in India and abroad.

Sunil was a joint country reporter for India at the 2011 Paris Congress of the International Fiscal Association on the subject of foreign tax credits. He was nominated as a tax controversy leader for India by International Tax Review readers for 2012.

Sunil holds a bachelor's in commerce from the University of Mumbai. He is a chartered accountant and a member of the Bombay Commerce of Chamber and Industry's tax and accounting committee.

I Park, Plot 15, Phase IV, Gurgaon

Delhi, 07 122001

India

Tel: +91 124 679 2261

Email: spsingh@deloitte.com

Website: www.deloitte.com

SP Singh advises multinational companies on international and domestic transfer pricing, encompassing documentation, planning, and controversy defence. SP is the chief negotiator for advance pricing agreements (APAs) and mutual agreement procedures (MAPs). He provides services to major multinational clients in a wide range of industries, including sourcing of apparel, software development, IT and ITeS, pharmaceutical, cosmetics, chemicals and energy. His clients are from various countries, including the US, the UK, Japan, Australia and France, apart from the Indian multinationals.

Before joining Deloitte India, SP was with the Indian Revenue Service for more than two decades. He held various positions in the service, including director of income tax (international taxation) and commissioner of income tax (appeals). He participated in the negotiation of tax treaties with more than 30 countries and took part in MAP discussions. He has represented India and presented papers at several international conferences. SP was a member of the expert group on transfer pricing constituted by the Ministry of Finance for drafting transfer pricing regulations. He also represented the Income Tax Department before the Authority for Advance Rulings in several cases.

SP has an MSc in fiscal studies from Bath University in the UK, and has earned a master's in physics from India. He is a member of the Bar Counsel of Income Tax Appellate Tribunal and is a regular faculty with the National Academy of Direct Taxes (apex training institute for Indian Revenue Service), Institute of Chartered Accountants of India, International Fiscal Association, and Indian Institute of Management, Lucknnow. He is co-chairman of the Direct Tax Committee of ASSOCHAM.

Recently, he was included in the 2013 Guide to the World's Leading Transfer Pricing Advisers by Euromoney. He has co-authored several white papers on TP related matters including APAs, safe harbour and so on and has co-authored two books on transfer pricing. He regularly contributes to international and national journals on taxation.

A-38, Kailash Colony

New Delhi – 110 048

India

Tel: +91 11 4163 9393

Direct: +91 11 4259 9245

Email: himanshu.sinha@trilegal.com

Website: www.trilegal.com

Himanshu Sinha leads the tax practice at Trilegal, one of India's leading full-service law firms. He represents and advises clients in a broad range of industries including trading, manufacturing, financial services, education, telecom and media, oil and gas, aerospace and defense and technology services.

Himanshu has more than 18 years of experience in direct taxes. He has extensive experience in managing complex tax controversies, especially in the field of transfer pricing and international tax. He regularly represents large multinational clients before courts, tribunals and authorities in litigation and audits. Many of the cases argued by him have been reported in law reports. Himanshu is also actively engaged in negotiating advance pricing agreements with the Indian government on behalf of well-known global companies. He also advises his clients on audit and litigation strategies and is actively engaged in defending directors and company officials in tax investigations and prosecutions.

Himanshu began his career with the Indian Revenue Service (IRS) where he served in various capacities during his 14 year stint with the government. He held numerous posts including assistant commissioner (business tax), deputy director (investigation), deputy director (international tax) and additional commissioner (transfer pricing) where he contributed significantly to the evolution of transfer pricing laws and procedures in India.

Before joining Trilegal, Himanshu was one of the leading resources in the tax controversy team of a Big 4 firm in India where he successfully defended many of his clients in high profile tax disputes.

Himanshu has a LLB from University of Delhi and a LLM from Harvard Law School. He was also chosen as one of the Gurukul Chevening scholars at the London School of Economics in 2001. He is affiliated with the Bar Council of India as an advocate and as a solicitor with the Solicitors Regulation Authority in the UK (non-practising status).

He has spoken at several international conferences and published articles with leading international journals. He has served as the country reporter for India for the 2012 IFA Boston Congress and 2014 IFA Mumbai Congress.

109 – A Wing

Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 22 6636 7000

Email: nareshthacker@elp-in.com

Naresh Thacker is a partner in the litigation and dispute resolution practice of Economic Laws Practice (ELP), specialising in tax and commercial disputes. He is a qualified lawyer with the additional attribute of being a qualified solicitor in England and Wales.

Naresh has successfully represented clients in matters pertaining to economic offences before various tribunals and courts in India. He is also actively involved in the field of alternate modes of dispute resolution and has managed a number of ICC, LCIA, SIAC, UNCITRAL, Swiss Rules and ad-hoc arbitrations. He has been part of mediation and conciliatory proceedings at the clients' behest and has brought them to fruition.

Naresh is active in a number of professional organisations including The Law Society, UK, London Court of International Arbitration (LCIA) and the All India Federation of Tax Practitioners (AIFTP). He is often quoted by prestigious international journals and his articles continue to appear in trade publications around the world.

PwC House, Plot 18/A

Guru Nanak Road

Bandra West

Mumbai – 400 064

India

Office: +91 22 6689 1332

Mobile: +91 9821319468

Fax: +91 22 6689 1888

Email: sanjay.tolia@in.pwc.com

Website: pwc.com/taxcontroversy

Sanjay is a partner with PwC and leads the India transfer pricing group. Sanjay has accumulated more than 22 years of experience including 16 years at PwC providing advisory services to medium and large sized multinational corporations.

Having chosen to specialise in transfer pricing at the inception of the Indian transfer pricing regime in 2001, he has gained extensive practical experience assisting clients across industries. Sanjay works closely with members of the PwC network around the world to provide consistent advice to clients.

He delivers value to his clients by matching their specific commercial realities and needs with in-depth economic analysis and a practical approach towards compliance requirements. He leads some of the large advance pricing agreement (APA) mandates for the firm and led the first two of the five APAs signed in India.

Sanjay is a chartered accountant and has a bachelor's degree in commerce and economics. He speaks regularly at tax seminars and industry conferences. He is also a lecturer at the Indian Institute of Management in Ahmedabad.