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

Rajiv Anand is a corporate tax partner with Deloitte India where he leads the tax litigation practice. Rajiv has more than 21 years of experience in domestic and international corporate taxation matters including cross-border restructurings, legal interpretations, in-depth analysis and strategic planning.

Rajiv has significant experience dealing with various domestic and international organisations in relation to handling and assisting in assessments and appellate proceedings up to the Indian Supreme Court (Apex Court).

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 partner in the tax and regulatory services, as well as head of tax dispute resolution, at BSR & Company, KPMG in India.

K R has more than 25 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.

He is the tax lead partner for the technology and software services sector. He is a fellow member of the Indian Institute of Chartered Accountants and an associate member of the Australian Taxation Institute. He holds a post graduate diploma in taxation practice from MS University, Baroda.

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 has more than 33 years of experience in various areas of direct tax law practice in India.

Pawan argues tax matters before the Commissioner (Appeals), Dispute Resolution Panel, tax tribunals, the Authority for Advance Rulings (AAR), etcetera.

He actively implements strategies for the entire life cycle of tax litigation and has an enviable record of supporting some of the world's biggest multinationals in their dispute resolution in India.

Pawan assists clients in various tax litigation matters before the high courts and the Supreme Court of India, having regard to judicial trends and anticipated tax legislation.

He has various firsts to his name and has obtained several pioneering rulings in the field of taxation of cross border transactions, as well as in transfer pricing.

Building No 10, Tower "C"

17th Floor, DLF Cyber City, Gurgaon

Haryana – 122 002

India

Tel: + 91 124 330 6501 (direct)

Mobile no: + 91 98300 55281

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

Website: pwc.com/taxcontroversy

Rahul Mitra is the national leader of the transfer pricing practice of PwC India. Rahul is a chartered accountant and honours graduate in commerce. Rahul has been a partner in the tax practice of PwC India since 1999.

Rahul has more than 20 years of experience in handling taxation and regulatory matters in India. He specialises in transfer pricing, particularly inbound and outbound planning assignments; he advises on profit/ cash repatriation planning; supply chain management projects; and profit attribution to permanent establishments, among other things.

Rahul independently handles litigation for large companies at the level of Income Tax Tribunals. At least 30 of the cases independently argued by Rahul have been reported in leading tax journals of India. Some of his major wins before the tribunal in transfer pricing matters are in the cases of GAP India; Development Consultants; Schefenacker Motherson; Intervet; Cheil Communications; Brinton Carpets; Fulford India and Ericsson.

Rahul is handling several advance pricing agreements (APA) in India, involving clients from across industries; and also covering complex transactions, such as 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 has been a paper-writer and a speaker at several tax conferences held in India and abroad. Rahul is a member of the global editorial board of Transfer Pricing Forum magazine, published by Bloomberg BNA.

He has been a visiting faculty of the National Law School in the subject of transfer pricing and international tax treaties. Rahul was the country reporter on the topic, Non Discrimination in international tax matters, for the IFA Congress held in Brussels in 2008.

Rahul was invited by the OECD to speak at the 2012 roundtable conference in Paris on developing countries' perspective on APAs.

Deloitte Centre, Anchorage II

100/2, Richmond Road

Bangalore 560 025

India

Tel: +91 80 6627 6105

Mobile: +91 98452 04631

Email: krsekar@deloitte.com

Website: www.deloitte.com

K.R. Sekar is a tax partner with Deloitte India and leads the International tax practice. Sekar has more than 25 years of experience in the field of direct tax, mergers and acquisitions, international taxation and transfer pricing. His clients include leading companies in technology, media, telecommunications, manufacturing, and engineering.

Sekar's key areas of expertise are inbound structuring, litigation support and advising on cross-border tax issues. He specialises in advising companies on tax risk mitigation and assisting in resolving tax controversies. Sekar is associated with many landmark litigation cases for global companies in the context of permanent establishment, withholding taxes, attribution of profit, and transfer pricing.

He also contributes regularly to tax journals. 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 – Bangalore Chamber of Industry & Commerce, a member of the India Board of the International Fiscal Association, and also works closely with other chambers including NASSCOM.

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

Sunil is a tax partner with Deloitte India, based in Mumbai. He previously headed the business tax service line for Deloitte India and is now a part of the international 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 also nominated as one of the tax controversy leaders for India by International Tax Review in 2012.

Sunil holds a B. Com from the University of Mumbai. He is a chartered accountant and a member of the Accounting and Taxation Committee of the Bombay Commerce of Chamber and Industry.

PwC House, Plot 18/A

Guru Nanak Road

Bandra West

Mumbai – 400 064

India

Tel: +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 western India transfer pricing group. Sanjay has more than 20 years of experience, including 15 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.

Over the years, he has successfully concluded a number of well documented tax audits on transfer pricing.

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 IIM, Ahmedabad.