India

Deloitte Haskins & Sells LLP

7th Floor, Building 10 Tower B

DLF Cyber City Complex

DLF City Phase II

(New Delhi / NCR)

Gurgaon, Haryana 122002

India

Tel +91 1246792141

Fax: +91 124 679 2012

Email: neahuja@deloitte.com

Website: www.deloitte.com

Neeru Ahuja, Deloitte India, is a global business tax partner based in the Gurgaon office. Neeru is also the Asia Pacific global business tax leader for Deloitte India and leads the tax brand and communication team in India. Neeru has more than 20 years of diverse experience in corporate and international taxation. Neeru's key areas of specialisation include corporate tax strategy and planning, tax litigation and controversy management, tax due diligence, tax and regulatory aspects of mergers and acquisitions, inbound investment advisory, and structuring cross-border transactions. Her client portfolio includes leading companies in consumer business, telecommunications, aerospace, and defence. Over the years, Neeru has developed a strong reputation in the area of tax controversy management, working with many well-known clients on several complex issues, including:

• Assisting clients in strategy formulation to manage tax litigation more efficiently, considering alternative dispute resolution mechanisms, scenario planning, and achieving closure;

• Assisting clients in resolving/mitigating their significant litigation issues;

• Assisting clients in representing their matters before various levels of tax authorities; and

• Representing industry on tax controversy issues with prominent chambers of commerce including meetings and committees set up by government.

In addition to advising clients, Neeru is actively involved with various reputable industry chambers and has been responsible for strengthening Deloitte's eminence in the marketplace. She is the co-chairperson of the American Chamber of Commerce (AMCHAM) tax and tariff committee, as well as a member of the tax committees of the Confederation of Indian Industry (CII), Federation of Indian Chambers of Commerce and Industry (FICCI) and the TDS committee of the Ministry of Finance. She is also a regular contributor to several leading tax journals and mainstream papers.

Deloitte Haskins & Sells LLP

Indiabulls Finance Centre, Tower 3 28th Floor, Senapati Bapat Marg, Elphinstone Road (West)

Mumbai 400013, Maharashtra

India

Tel: +91 22 6185 4040

Fax: +91 22 6185 4101

Email: cgupta@deloitte.com

Website: www.deloitte.com

C A Gupta (CAG), Deloitte India, is a tax partner in the Mumbai office. He has vast experience of approximately 25 years.

Over this time, CAG has advised various multinationals as well as domestic clients on their Indian and international projects.

CAG specialises in domestic and international taxation, and exchange control regulations. He has advised clients on various complex issues relating to inbound as well as outbound structuring. He has assisted multinational companies on tax considerations in relation to setting up operations in India. He has also advised large institutional investors on their Indian investments. He has guided clients on various aspects of deputation structuring, including permanent establishment exposure, etc.

CAG has also represented and supported clients before various tax and appellate authorities and other forums like the Income Tax Appellate Tribunal, Authority for Advance Ruling, etc. on various contentious tax issues.

His key areas of focus are tax advisory, tax compliance and tax controversy management, covering domestic tax law as well as various aspects of tax treaties.

CAG is a fellow member of the Institute of Chartered Accountant of India (ICAI). He is an alumna of the University of Mumbai, with a bachelor's degree in commerce as well as law.

CAG has also been an active contributor to various initiatives of the ICAI. He has contributed to the study publication for the diploma course on international taxation by the ICAI. He has been invited to speak at the said course from time to time. In addition, he has also been a speaker at various conferences and seminars discussing income tax issues.

Deloitte Haskins & Sells LLP

Indiabulls Finance Centre, Tower 3, 28th floor

Senapati Bapat Marg, Elphinstone Mill Compound

Elphinstone (W)

Mumbai – 400 013

India

Tel: +91 22 61854288

Fax: +91 22 61854101

Email: manishagupta@deloitte.com

Website: www.deloitte.com

Manisha Gupta, Deloitte India, has more than 18 years of experience in the fields of transfer pricing and international tax and has been a part of the Deloitte transfer pricing team since June 2009.

Over the past years, Manisha has provided transfer pricing services to leading multinationals across a range of industries such as pharmaceutical, infrastructure, FMCG, software and ITES, hospitality, and more. She is actively involved in providing litigation support in substantial intercompany pricing cases, transfer pricing planning and documentation projects to determine arm's-length compensation for tangible property, intangible property and services.

Manisha has represented leading trans-national companies at the field level and appellate level on complex transfer pricing issues and assisted companies in resolving disputes through the alternate dispute resolution mechanisms i.e. MAP/APA. She has contributed numerous articles on transfer pricing to various journals and is a regular speaker at various forums. Manisha is a member of the Institute of Chartered Accountants of India and has previously worked with EY and KPMG.

Manisha has been recognised as one of the 30 leading tax controversy advisers published by International Tax Review for the consecutive years in 2014, 2015 and 2016 and as a leading woman in tax in India for 2015 and 2016.

Manisha is a chartered accountant by qualification and is a fellow member of the Institute of Chartered Accountants of India. She also holds a bachelor's degree in commerce.

Economic Laws Practice

Tel: +91 22 6636 7000

Mobile: +91 90046 04350

Email: rohitjain@elp-in.com

Rohit Jain is a partner at ELP and co-heads the tax practice focusing not only on indirect taxes, direct tax and transfer pricing but also on the newly introduced goods and services tax (GST). He is a law graduate from the University of Mumbai and a fellow member of the Institute of Chartered Accountants of India (ICAI). His areas of expertise include customs, excise, service tax, central sales tax (CST), state value added tax (VAT) laws and foreign trade policy (FTP).

Rohit has been with the firm since its very inception and has more than a decade of experience in handling matters related to tax, in both advisory and litigation matters. He has advised various Fortune 500 companies and Indian conglomerates in sectors like financial services, manufacturing, telecommunication, oil and gas, petroleum and infrastructure projects to ensure smooth transitions from sales tax to the VAT regime. He has also been involved in making representations to the Ministry of Finance and the Ministry of Commerce in relation to various tax policy matters on behalf of numerous industry associations.

Rohit has been recognised for his expertise in tax by Chambers Asia-Pacific (2014 to 2017), has been recommended by the Tax Director's Handbook 2012 and has also featured in World Transfer Pricing 2015.

Prior to joining ELP, Rohit was part of the tax team at RSM & Co.

Deloitte Haskins & Sells LLP

100/2, Anchorage I, Richmond Road

Bangalore

India

Tel: +91 80 6627 6130

Fax: +91 80 6627 6430

Email: krsubramanian@deloitte.com

Website: www.deloitte.com

Subramanian Krishnamani (Subbu), Deloitte India, has 19 years of experience in providing taxation services specialising in complex advisory and litigation matters.

He has hands-on experience in litigation matters with a special focus on strategising at all levels of representation and litigation. He has been successful for a wide range of multinational and global domestic clients in obtaining rulings, defending audits and gaining relief at appellate levels on a wide range of difficult and multifaceted tax issues including withholding tax matters.

His twin beliefs of "path to success" and "path of least resistance" have helped many clients achieve significant success in navigating intricate litigation matters.

Using his deep acumen on the entire litigation lifecycle he has advised clients on a gamut of complex cross-border structures, restructuring, and business model optimisation.

Subbu holds a BCom degree and is a fellow member of the Institute of Chartered Accountants of India. Subbu is also an avid speaker on tax matters and loves sharing his experiences at professional gatherings. He also writes extensively on his perspective of various tax matters.

Krishnomics Legal

N-117 (LGF)

Panchsheel Park

New Delhi-110 017

India

Tel: +91 11 65092194

Email: gagan@krishnomicslegal.in

Website: www.krishnomicslegal.in

Gagan Kumar is a commerce graduate from Delhi University and a member of the Bar Council of Delhi and a fellow member of the Institute of Chartered Accountants of India.

Prior to setting up Krishnomics Legal, Gagan was principal associate with one of the largest law firms in India. Gagan has also worked with a Big 4 firm and brings with him more than 19 years of experience.

He has extensive experience in litigation and advisory aspects of the tax practice. He has successfully represented various corporates before the Supreme Court, High Court and Income Tax Appellate Tribunal (ITAT), Central Excise and Service Tax Appellate Tribunal (CESTAT) and Commissioner of Income Tax (Appeals).

Gagan has been recognised as:

• One of the tax controversy leaders by International Tax Review in 2016, 2015, 2014 and 2013;

• India's leading corporate tax lawyer by the International Who's Who Legal in 2012;

• An exclusive member for corporate tax of international network of law firms called The Lawyer Network; and

• Adjudged as one of the top 10 start-ups in the legal sector by Startup City Magazine in April 2017.

He has been a regular speaker on various national and international forums. Gagan is a member of the Delhi High Court Bar Association and of the American Bar Association. He has contributed articles to various national and international journals. Gagan also sits on the board of several companies as an independent director. He is also actively involved with the Rotary Club.

Over the years, Gagan has advised a number of domestic and international companies on tax issues relating to corporate tax, transfer pricing, mergers and restructuring, tax prosecution, value added tax, central excise, custom, service tax, etc. He has advised on structuring options to various private equity funds.

Gagan has represented various companies before the Supreme Court and Delhi High Court. He has also appeared as an expert witness before the Permanent Court of Arbitration, The Hague.

Gagan has advised many not-for-profit organisations from a tax and regulatory laws perspective including the Foreign Contribution Regulations Act. He has also advised leading multinational charities functioning in India. He has helped in setting up public charitable trusts for the welfare of destitute lawyers. He has been actively associated with helping not-for-profit organisations on a pro bono basis.

Economic Laws Practice

Tel: +91 79 6605 4480

Mobile: +91 98258 00523

Email: hardikmodh@elp-in.com

Hardik Modh is a partner in the litigation and dispute resolution team of ELP and is based in Ahmedabad. He completed his graduation in law from the University of Gujarat in 2002 and chartered accountancy from the Institute of Chartered Accountant Association of India.

Hardik renders litigation and advisory services in indirect taxation, commercial litigation, and white collar criminal offences. He has more than 13 years of experience in rendering such services and has successfully handled various cases. He appears before various statutory authorities, tribunals, consumer forums, civil courts and high courts. He writes articles and presents seminars on the law and practice of indirect tax.

Prior to ELP, he worked with R V Desai, senior advocate, Vikram Nankani, senior advocate, and then shifted to Ahmedabad and started his own practice.

Economic Laws Practice

Tel: +91 22 6636 7000

Mobile: +91 90046 75996

Email: jitendramotwani@elp-in.com

Jitendra Motwani is a partner with ELP's litigation and dispute resolution practice in Mumbai.

Jitendra graduated from KC Law College, Mumbai in 2003 and obtained his solicitor's qualification from the Bombay Incorporated Law Society in 2006.

Jitendra's area of specialisation covers all forms of indirect taxes including central excise, customs, sales tax/VAT and service tax as well as the foreign trade policy. Apart from advising clients on various aspects of indirect tax laws he also actively appears before various forums including the Supreme Court of India, high courts, tax tribunals and all quasi-judicial authorities across India.

Jitendra has written several articles in varied publications and is regularly called upon by professional bodies to speak at conferences and seminars.

Prior to ELP, Jitendra was with PDS Legal and DSK Legal.

Deloitte Haskins & Sells LLP

Deloitte Centre, Anchorage I, 100/2, Richmond Road

Bangalore – 560025

India

Tel: +91 80 66276105

Fax: +91 80 66276405

Email: krsekar@deloitte.com

Website: www.deloitte.com

KR Sekar, Deloitte India, is a tax partner and leads the global business tax practice. He is a member of the Deloitte India board. He is also the regional practice leader for Deloitte South India and Sri Lanka. Sekar has more than 25 years of experience in the field of direct taxes, mergers and 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, tax controversy management and advising on cross-border tax issues. He advises inbound global companies on entry strategies, inbound structuring and assists them on mitigating tax risks.

Sekar works closely with several reputed clients on litigation and tax controversy management related matters. He has successfully led several cases on critical issues relating to litigation. He has also assisted global clients with path-breaking resolutions on critical tax issues. He has been associated with many landmark litigation cases for global companies.

In addition to advising clients, Sekar is active in representing before the government on various tax issues impacting industry through his positions in the Chambers of Commerce. He is also a prolific writer, contributing regularly to tax journals and mainstream newspapers. He has written 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 direct taxes expert committee for the Bangalore Chamber of Industry & Commerce. He is also a member of the India board of the International Fiscal Association and also works closely with other chambers including NASSCOM. He is the founder director of the International Tax Research and Analysis Foundation (ITRAF), which is a dedicated research body in the field of international tax.

Economic Laws Practice

Tel: +91 22 6636 7000

Mobile: +91 90046 04323

Email: nishantshah@elp-in.com

Nishant Shah is a partner in the tax practice of ELP, focusing on indirect taxes. He is a qualified lawyer and a chartered accountant. His areas of expertise include excise, customs, service tax, central sales tax, state levies and regulations under the Foreign Trade Policy.

Nishant has worked extensively with the state governments of Rajasthan and Punjab during the introduction of the value added tax (VAT) regime in India. He has worked extensively with various industry associations and assisted them in successfully representing before the central government or state governments for granting reliefs from concerns faced by these associations. He has tremendous experience and expertise on matters relating to special economic zones.

As part of a new initiative, Nishant has been working on developing expertise in relation to the anti-money laundering, anti-corruption and allied laws recently introduced in India, including its implications for various industries.

Nishant has been recommended for his expertise in tax by the Legal 500 Asia-Pacific 2016.

Prior to ELP, Nishant was part of the tax teams at KPMG and Deloitte.

Chambers of Rohan Shah

1502 A, Dalamal Towers

Free Press Journal Roa

Nariman Point

Mumbai 400 021

India

Tel: +91 22 2287 3131/ 0101

Mobile: +91 99670 23300

Email: rohan@shahchambers.in

Rohan Shah is a practicing counsel in the Bombay High Court and Supreme Court. He received his law degree from the Government Law College of Bombay University (now the University of Mumbai). After his LLB, he worked with Crawford Bayley and Co, Advocates and Solicitors in Mumbai (1988-1989). In 2001, Rohan founded Economic Laws Practice (ELP), a leading law firm in India. He was the managing partner of ELP from 2001 to 2016 and then moved on to practice as an independent counsel.

Renowned for his practical knowledge of India's indirect, domestic, and international taxation codes and policies, Rohan has been appointed to various expert committees formed by the Indian Ministry of Finance and the Indian Ministry of Commerce. He was a member of the Indian commerce minister's negotiating team at the World Trade Organisation ministerial conferences in Seattle in November 1999. He was recently appointed as legal expert of the Central Board of Excise and Customs sub-committee constituted by the Ministry of Finance in March 2016 to investigate all issues relating to the imposition of excise duty on jewellery.

Rohan has been listed as a leading lawyer in India for his expertise in taxation and technology, media and telecommunications practices by The Legal500 Asia Pacific and Chambers Asia-Pacific (2009–2016); and as a market leader by Asialaw Profiles (2016).

International Tax Review has consistently recognised his status as a leading tax lawyer in the Indirect Tax Leaders guide, while Tax Directors Handbook also recommended him (2007–2016). He has also been selected among the "100 leading tax lawyers in the world" by Who's Who Legal: Corporate Tax (2009), and named as a "leading lawyer" by Who's Who Legal: Corporate Tax (2010–2017) and Who's Who Legal: Trade & Customs (2013 to 2017). Rohan has featured in Asian Legal Business's "hot 100" list in 2010, and was named in the January 2000 edition of India Today as one of the "50 Indians for the next millennium". He was recognised as the exclusive winner in the corporate tax category in India at the Client Choice Awards (2014 and 2015), and as a leading tax controversy adviser in India by ITR's Tax Controversy Leaders guide (fourth, fifth and sixth editions).

Rohan is a qualified solicitor and is also authorised to practice in England and Wales, as a member of the Law Society.

Deloitte Haskins & Sells LLP

7th Floor, 10-B, DLF Cyber City

Gurgaon, Haryana

India

Tel: +91 (124) 679 2261

Fax: +91 (124) 679 2012

Email: spsingh@deloitte.com

Website: www.deloitte.com

S P Singh (SP as he is known), Deloitte India, is a senior director in the Delhi office. He advices multinational companies on international and domestic transfer pricing, encompassing documentation, planning, and controversy defence.

SP is Deloitte India's chief negotiator for advance pricing agreements (APAs) and mutual agreement procedures (MAPs). He is also leading the tax litigation practice in Deloitte India. He provides services to major multinational clients in a wide range of industries, including sourcing of apparel, software development, IT and ITeS, pharmaceuticals, cosmetics, chemicals, and energy. He serves clients from various countries, including Australia, France, Japan, UK, and the US, in addition to Indian multinationals.

Before joining Deloitte, SP was with the Indian Revenue Service for more than two decades. He held various positions, 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 MAPs. He has represented India in several international conferences and presented papers. He was a member of the expert group on transfer pricing constituted by the Ministry of Finance for drafting the transfer pricing regulations. He represented the income tax department before the Authority for Advance Rulings in several cases.

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

SP has been named in Euromoney/Legal Media's guide to the world leading transfer pricing advisers and International Tax Review has recognised him as one of the global leaders in tax litigation and as a leading TP expert for 2014, 2015 and 2016. He has co-authored several white papers on transfer pricing matters such as APAs and safe harbour rules, and has co-authored two books on transfer pricing. He regularly contributes to international and national journals on taxation.

Deloitte Haskins & Sells LLP

7th Floor, ASV N Ramana Towers

52, Venkatanarayan Road, T Nagar

Chennai – 600 017

India

Tel: +91 44 6688 5000

Fax: +91 44 6688 5050

Email: srajesh@deloitte.com

Website: www.deloitte.com

Rajesh Srinivasan, Deloitte India, heads the tax practice in Chennai, India. Rajesh also leads the manufacturing vertical in Deloitte India's tax practice besides heading the south India cluster of global business tax service line.

Rajesh has more than 24 years of tax consulting experience. He has served clientele that spans across all major industries including automotive original equipment manufacturers (OEMs) and component manufacturers, pharmaceuticals, infrastructure and engineering products and services as well as companies engaged in information technology and IT-enabled services.

Rajesh serves as Deloitte India's lead client service partner/lead tax partner for a number of automotive OEMs as well as other manufacturing clients.

Rajesh has advised clients on entry strategies, corporate restructurings, mergers and amalgamations, outbound investment planning, transfer pricing, employee international assignment programmes and on routine corporate tax issues.

Rajesh has supported clients on complex tax issues such as tax positions to be taken during initial years of operations, tax holidays/incentives, incubation related expenses, cross-border transactions including issues relating to permanent establishments, employee secondment, foreign tax credit, etc. and has also successfully defended the tax positions before the income tax/appellate authorities. He has the ability to approach tax issues meticulously by bringing an array of tax consulting and technical experience to the table with a practical mind-set. His competency lies in coming out with unique solutions to practical challenges faced by businesses in the application of tax laws backed by strong conceptual understanding and deeper technical knowledge.

Besides helping clients in evaluating alternate options (such as filing of writ petitions, engaging on mutual agreement procedures, etc.) available for speedy disposal of tax disputes, Rajesh also guides in managing the litigation in an effective way in the years to come.

Rajesh is a regular speaker at various tax conferences organised by the International Fiscal Association, Industry Chambers, etc. and also a faculty at the international tax post qualification diploma programme of the Institute of Chartered Accountants of India.

Rajesh holds a bachelor's degree in commerce and is a member of the Institute of Chartered Accountants of India, Institute of Cost and Works Accountants of India and Institute of Company Secretaries of India.

Economic Laws Practice

Tel: +91 22 6636 7000

Mobile: +91 98212 37857

Email: nareshthacker@elp-in.com

Naresh Thacker is a partner in the litigation, arbitration and dispute resolution practice at ELP. He is a qualified lawyer with the additional attribute of being a solicitor (non-practising) in England and Wales.

Naresh has more than 19 years of experience in litigation, international arbitration and mediation; particularly in large infrastructure project arbitrations and post M&A arbitrations, corporate litigation, commercial disputes, regulatory and tax disputes and white collar crimes. Over the years he has handled a number international and national arbitration cases as counsel under the rules of the International Chamber of Commerce (ICC), Singapore International Arbitration Centre (SIAC), London Court of International Arbitration (LCIA), the United Nations Commission on International Trade Law (UNCITRAL), Swiss rules and ad-hoc proceedings for both domestic and multinational clients. He has been part of mediation and conciliatory proceedings at the clients' behest and has achieved successful results for his clients.

Naresh's experience in tax disputes span issues relating to indirect tax, including central excise, customs, service tax and VAT. On the regulatory front he routinely advises and represents clients on foreign exchange related issues and electricity matters. He has successfully represented clients in matters pertaining to economic offences before diverse tribunals and courts in India, a large number of which have industry-wide implications. Such decisions have been widely reported in various legal journals such as ELT, RLT, AIR, TIOL, Taxsutra, etc.

Naresh is active in a number of professional organisations including the Law Society, UK, London Court of International Arbitration (LCIA), International Bar Association (IBA), and the All India Federation of Tax Practitioners (AIFTP).

Naresh is also an eloquent and much sought after speaker who has spoken at various seminars on international arbitration and tax laws organised by, amongst others, LCIA, IBA, AIFTP, Corporate Counsels Association of India (CCAI), Chamber of Tax Consultants (CTC), etc.

Naresh is often quoted by prestigious international journals and his articles continue to appear in trade publications around the world such as International Law Offices, India Business Law Journal, and Global Arbitration Review (GAR). He is also frequently sought out for his comments and insights by leading newspapers such as the Economic Times, Business Today, Live Mint and Financial Express. He has written the India Chapter for The Asia-Pacific Arbitration Review 2016 and 2017 published by GAR, and the International Arbitration 2016 Global Practice Guide published by Chambers & Partners. Naresh has been featured as a leading tax controversy adviser in India in Tax Controversy Leaders (fourth, fifth and sixth editions) and as an expert in World Tax 2015.

Price Waterhouse & Co LLP

Mobile: +91-9962095555

Email: kunj.vaidya@in.pwc.com

Website: pwc.com/taxcontroversy

Kunj Vaidya is the national transfer pricing leader in India.

He has more than 17 years of experience in providing quantitative and strategic analyses to companies interested in establishing pricing policies. This includes providing assistance in accordance with transfer pricing requirements in the US, Australia, and India.

His experience includes transfer pricing audit defence, advance pricing agreements (APAs), planning studies and global documentation for compliance requirements. In his career as a transfer pricing specialist, he has worked on several APAs involving various jurisdictions – Australia, Canada, Germany, Japan, the UK and the US. He has also been closely involved with number of APA matters with India over the past several years.

Kunj has also assisted companies with operational transfer pricing, both in planning and implementation phases; and intellectual property (IP) migration, including buy-in payment structuring, valuation and planning related aspects. While he has worked across industries, his primary focus has been the automotive industry, including original equipment manufacturers, tier one and tier two suppliers.

Kunj has been actively engaged in several speaking engagements including Confederation of Indian Industry forums, Institute of Financial Accountants conferences, etc. He has also contributed to several thought leadership articles related to transfer pricing in various publications including Bloomberg BNA, International Tax Review, Tax Sutra, The Hindu, Business Line, Dalal Street, etc. Kunj frequently gives opinion to financial dailies and has recently penned his views on 'TP for the future' in the Financial Express. He also led the efforts and co-authored India's first comprehensive White Paper on APAs as early as 2011, before the start of the Indian APA programme.

Kunj is a chartered accountant and has a master's degree in commerce. He has also completed his master's in business administration from Sam Walton School of Business, US, and is a certified public accountant from the US.