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: +91 124 679 2141 (Work)

Mobile: +91 9811101589

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 over 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

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, Deloitte India, is a corporate tax partner in the global business tax practice in India. He has over 25 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.

The core areas of Rajiv's experience includes international taxation, due diligence and 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. In addition, he specialises in advising clients on various regulatory, corporate and tax aspects of corporations doing business with/in India, dealing with various domestic and international multinationals in relation to handling their corporate and withholding tax assessments and appellate proceedings including courts.

Rajiv's experience also includes analysing the constitutional validity of statutory provisions including retrospective amendments and advising clients on the same and day-to-day advisory and compliance support to MNE clients.

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

Deloitte Haskins & Sells LLP

India Bulls 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, Deloitte India, is a partner in the transfer pricing practice. She has more than 15 years of experience in the fields of transfer pricing and international tax and has secured some key transfer pricing litigation in India.

Since joining Deloitte India, Manisha has assisted leading Indian and foreign multinational enterprises 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, MAPs, 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, among others.

Manisha is a frequent speaker on transfer pricing topics. She has written and co-authored various articles on transfer pricing controversies, alternate dispute resolution, and other topics. She is a member of the Institute of Chartered Accountants of India.

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, as well as a fellow member of Institute of Chartered Accountants of India.

Before setting up Krishnomics Legal, Gagan was principal associate with one of the largest law firms of India. Gagan has also worked with Big 4 accounting firms and brings with him more than 17 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) and Commissioner of Income Tax (Appeals), Dispute Resolution Panel of Income Tax, Central Excise & Service Tax Appellate Tribunal, National Consumer Dispute Redressal Commission, among others.

Gagan has been recognised as India's leading corporate tax lawyer by Who's Who Legal in 2012 and as a tax controversy leader by International Tax Review in 2013 and 2014.

He has been a regular speaker at 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 various articles to national and international journals.

Over the years, Gagan has advised a number of domestic and international companies on tax issues relating to corporate tax, transfer pricing, mergers and restructurings, value added tax (VAT), central excise, customs, service tax and others. He has also advised on structuring options to various private equity funds.

Gagan has advised many not-for-profit organisations from a tax and regulatory laws perspective including compliance with the Foreign Contribution Regulations Act. He has advised leading multinational charities functioning in India. He is actively associated with platforms helping not-for-profit organisations on a pro bono basis.

Deloitte Haskins & Sells LLP

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, Deloitte India, is a tax partner and leads the global business tax practice. He is also the regional practice leader for Deloitte South India. Sekar has over 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 and tax controversy management, and advising on cross-border tax issues. He advises inbound global companies on entry strategy, inbound structuring and assists them on mitigating tax risks.

Sekar works closely with several reputable 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 position 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 Judgments of Supreme Court on Direct Tax Laws: An Analysis'.

Sekar is the chairman of the direct taxes expert committee for the Bangalore Chamber of Industry & Commerce. He is also a member of the India board of International Fiscal Association and also works closely with other chambers including NASSCOM. He is the founder director of International Tax Research and Analysis Foundation (ITRAF), which is a dedicated research body in the field of international tax.

Economic Laws Practice

109 – A Wing, Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 22 6636 7000

Mobile: + 91 99670 23300

Email: rohanshah@elp-in.com

Website: www.elplaw.in

Rohan Shah is the managing partner at Economic Laws Practice (ELP) and leads the tax practice.

Rohan received his law degree from the Government Law College of the Bombay University. After his LLB, he worked with Crawford Bayley and Co., Advocates and Solicitors in Mumbai from 1988 to 1989. In 2001, Rohan co-founded ELP, a leading full-service law firm in India that has offices in six cities and a team of over 130 professionals.

Rohan is a qualified solicitor and as a member of the UK Law Society. He is authorised to also practice in England and Wales. He is well known for his expertise in advisory, policy and controversy issues related to indirect taxes (excise tax, 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 Supreme Court, various high courts and the tribunals, resulting in several reported judgments in the areas of indirect tax and trade remedial disputes.

Rohan has been appointed to various expert committees formed by India's Ministry of Finance and Ministry of Commerce on issues related to the introduction of presumptive taxation for the gems and jewellery sector. He was also a member of the Indian Commerce Minister's negotiating team at the WTO ministerial conferences in Seattle, held in November 1999. At present, he is the legal expert on the CBEC sub-committee constituted by the Ministry of Finance in March 2016 to look into 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 TMT practices by Asia Pacific Legal 500 and Chambers Asia-Pacific from 2009 until 2016, and by Asialaw Leading Lawyers from 2013 to 2015. International Tax Review hailed him as being among the leading tax lawyers in the world, while the Tax Directors Handbook recommended him from 2007 to 2016. He has also been selected as a leading lawyer by Who's Who Legal – Corporate Tax from 2010 to 2016 and in Who's Who Legal – Trade & Customs from 2013 to 2016. Rohan was featured in Asian Legal Business Hot 100 in 2010 and India Today's January 2000 edition as one of the '50 Indians for the Next Millennium'. He won the Client Choice Awards 2014 in India for corporate tax, as a leading tax controversy adviser in India by Tax Controversy Leaders (4th, 5th and 6th editions). World Transfer Pricing 2015 listed him as a leading individual for transfer pricing advisory services, while Benchmark Asia-Pacific 2014 said he is a Leading Disputes Star in India.

Deloitte Haskins & Sells LLP

iPark, Plot 15, Phase IV, Gurgaon

Delhi, 07 122001

India

Tel: +91 124 679 2261

Email: spsingh@deloitte.com

Website: www.deloitte.com

SP Singh, Deloitte India, advises multinational enterprises on international and domestic transfer pricing, encompassing documentation, planning, and controversy defence. SP is the head of the tax controversy management practice and 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. Apart from Indian multinationals, his clients are from various countries, including the US, the UK, Japan, Australia and France.

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 MAPs. He has represented India in several international conferences and presented papers. 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 a master's degree in physics from India. He is a member of the Bar Counsel of Income Tax Appellate Tribunal and is a regular contributor at the National Academy of Direct Taxes (apex training institute for the Indian Revenue Service), Institute of Chartered Accountants of India, International Fiscal Association, and Indian Institute of Management, Lucknow. He is co-chairman of the direct tax committee of ASSOCHAM. SP was included in 2013 and Euromoney's 2014 Transfer Pricing Expert Guide and has been named as a leading tax controversy leader for 2014 and 2015. He has co-authored several white papers on transfer pricing-related matters including APAs and safe harbour provisions, among others, and has co-authored two books on transfer pricing.

He regularly contributes to international and national journals on taxation.

Trilegal

Partner

311B DLF South Court

Saket

New Delhi – 110017

India

Tel: + 91 11 4163 9393

Dir: + 91 11 4259 9245

Email: Himanshu.Sinha@trilegal.com

Himanshu Sinha leads the tax practice at Trilegal, one of India's largest and leading full-service law firms. Himanshu has more than 20 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 MNE clients before courts, tribunals and authorities in high-stake litigation, negotiation and audits. Many of the cases argued by him have been reported in law reports.

His clients are from a broad range of industries including trading, manufacturing, financial services, education, telecommunications and media, oil and gas, aerospace and defence and technology services. He has represented companies like Motorola, British Airways, Airbus, Sumitomo, Marubeni-Itochu, LinkedIn, Toshiba, Alcatel, Exxon Mobil, Ariba and Bestseller, Henkel and Cowi in complex tax litigations involving transfer pricing, permanent establishments, treaty interpretations, income-characterisations, EPC and infrastructure projects and business restructurings.

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. He is also actively engaged in defending directors and company officials in tax investigations and prosecutions.

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

Prior to 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 the 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 Solicitors Regulation Authority, UK (non-practicing status).

Economic Laws Practice

109 – A Wing, Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 22 6636 7000

Mobile: +91 98212 37857

Email: nareshthacker@elp-in.com

Website: www.elplaw.in

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

Naresh has successfully represented clients in matters pertaining to economic offences before diverse 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 currently 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. He has been featured as a leading tax controversy adviser in India by the Tax Controversy Leaders (4th, 5th and 6th editions) and as an expert in World Tax 2015.

Prior to ELP, Naresh practiced as an independent counsel on indirect tax and litigation matters.

Economic Laws Practice

109 – A Wing, Dalamal Towers

Nariman Point

Mumbai 400021

India

Tel: +91 11 4152 8400

Mobile: +91 99714 99911

Email: alokyadav@elp-in.com

Website: www.elplaw.in

Alok Yadav is a partner in the litigation and dispute resolution practice of Economic Laws Practice (ELP). Based in Delhi, he specialises in tax-related disputes.

Alok's expertise spans across several aspects of law including customs, central excise, service tax and litigation matters related to indirect taxes. He has appeared in more than 250 matters independently before the Supreme Court for clients such as PepsiCo, Hewlett Packard, Bharti Airtel, Cargill India, Nestlé India and Kelvinator Electrolux.

Alok holds a law degree from Delhi University and is a member of the Supreme Court Bar Association.

With over 14 years of experience as a legal professional in the areas of direct and indirect tax litigation, Alok started his career as a lawyer with J.B. Dadachanji and Co. in Delhi in 2000. Since leaving that firm he has been associated with Lakshmikumaran & Sridharan Attorneys.

Alok has recently featured as a leading tax controversy adviser in India in Tax Controversy Leaders (5th and 6th editions).