Assistant Manager / Manager - Direct Tax

Bhuta Shah & Co; Mumbai City; On-site; INR 1,200,000 - 2,000,000; Full time

Job summary

Bhuta Shah & Co in Mumbai Nariman Point seeks an Assistant Manager / Manager in Direct Taxation Advisory & Regulatory Services. The role covers litigation, assessment, transfer pricing, and advisory work, with exposure to high-stakes tax matters and appellate proceedings.

You will draft submissions, coordinate with partners, and manage client engagements, ensuring timely responses and compliance for various entities. CA with 3+ years PQE and strong drafting and research skills are required.

Qualifications

• CA with minimum 3 years post-qualification experience in direct taxation
• Experience in direct tax litigation, appellate proceedings, and representation
• Articleship in a mid-size/large CA firm; prior professional services experience preferred

Responsibilities

• Draft, review, and prepare appeals, grounds of appeal, statements of facts, and paper books for CIT(A) and ITAT.
• Handle matters under Faceless Appeal Scheme and other appellate authorities.
• Conduct legal research, analyse precedents, and develop litigation strategies for appellate matters.
• Prepare submissions for assessment, reassessment, penalties, stay, and prosecution proceedings.
• Assist in briefing Partners, Senior Counsels, and preparing case summaries and precedents.
• Support representation before tax authorities, coordinate hearings, and track deadlines.
• Monitor litigation matters, evaluate tax demands, and advise on remedies.

Skills

Taxation knowledge

Drafting & submissions

Legal research

Communication & presentation

Team collaboration

Tax filing proficiency

Education

Chartered Accountant

Tools

Tax software

Research tools

Accounting software

Job description

Job Description

Department: Direct Taxation Advisory & Regulatory Services

Job Title: Assistant Manager / Manager

Location: Mumbai Nariman Point

Reporting To: Senior Manager / Partner

Experience & Qualification

• Chartered Accountant (CA).
• Minimum 3 years of post-qualification experience in direct taxation, with exposure to direct tax litigation, appellate proceedings, and representation.
• Articleship experience with a mid-sized or large CA firm; prior experience with a professional services firm is preferred.

Key Competencies

• Strong technical knowledge of the Income-tax Act, 1961, applicable rules, and relevant judicial precedents.
• Excellent drafting, legal research, analytical, communication, and presentation skills.
• Ability to prepare high-quality written submissions, grounds of appeal, paper books, and legal briefs.
• Proactive, self-driven, detail-oriented, and result-oriented approach, with the ability to work effectively in a team.
• Proficiency in electronic tax filings, documentation, research tools, and computerised working environments.

Key Responsibilities

1. Direct Tax Litigation, Appeals & Representation

• Draft, review, and prepare appeals, grounds of appeal, statements of facts, written submissions, paper books, and supporting documentation for proceedings before the Commissioner of Income Tax (Appeals) [CIT(A)] and the Income Tax Appellate Tribunal (ITAT).
• Handle appellate matters under both the Faceless Appeal Scheme and before jurisdictional appellate authorities.
• Conduct detailed legal research on complex tax issues, analyse judicial precedents, and develop arguments and litigation strategies for appellate matters.
• Prepare submissions and responses for assessment, reassessment, penalty, stay, and prosecution proceedings, including matters arising from search and seizure operations.
• Assist in briefing Managers, Partners, and Senior Counsels for matters before CIT(A), ITAT, High Courts, and the Supreme Court, including preparation of case summaries, paper books, and compilation of relevant judicial precedents.
• Support representation before income-tax authorities and appellate forums, including coordination of hearings, filing of submissions, and follow-up on proceedings.
• Monitor litigation matters, track deadlines, and assist in evaluating tax demands, potential exposures, and appropriate legal remedies.

2. Assessment Proceedings & Direct Tax Compliance

• Draft submissions and responses to notices, queries, and requisitions issued by the Assessing Officer and other income-tax authorities.
• Assist in assessment, reassessment, transfer pricing assessment, and other regulatory proceedings.
• Prepare, review, and file income-tax returns and TDS returns for individuals, HUFs, partnership firms, and companies.
• Respond to departmental notices and ensure timely compliance with statutory requirements.
• Review tax audit reports and assist in other direct tax compliance, certification, and filing requirements.

3. Transfer Pricing & International Taxation

• Prepare and review transfer pricing study reports, including conducting Functional, Asset and Risk (FAR) interviews and analysing comparable companies and transactions.
• Assist in transfer pricing assessments and proceedings before the Transfer Pricing Officer (TPO).
• Prepare and review Form No. 3CEB, inter-company agreements, and transfer pricing documentation.
• Assist in the preparation of Advance Pricing Agreement (APA) pre-filing applications and applications, including rollback provisions.
• Undertake Base Erosion and Profit Shifting (BEPS) analysis and assist with Country-by-Country Reporting (CbCR) and Master File compliances.
• Advise on domestic and international tax issues, including cross-border transactions, Double Taxation Avoidance Agreements (DTAAs), Multilateral Instruments (MLIs), permanent establishment exposure, inbound and outbound taxation, and repatriation of funds.
• Prepare and review Form 15CA/15CB and analyse withholding tax implications for domestic and cross-border transactions.

4. Tax Advisory, Structuring & Planning

• Assist in providing advisory on domestic taxation, international taxation, corporate tax, and transfer pricing matters.
• Evaluate the tax implications of business transactions, corporate structures, and proposed arrangements.
• Support tax planning and structuring assignments, including identifying tax risks and evaluating available tax positions.
• Assist in preparing technical opinions, advisory notes, client responses, and research memoranda on complex tax matters.

5. Client Management & Practice Development

• Support Partners and Managers in day-to-day assignments, client deliverables, and resolution of technical tax queries.
• Coordinate with clients to obtain information, understand transaction details, and ensure timely completion of assignments.
• Contribute to technical updates by tracking amendments to tax laws, reviewing professional publications, and analysing relevant judicial pronouncements.
• Assist in preparing proposals, client presentations, engagement documents, and other practice development materials.

Tools & Software

Working Days: 5 Days (Mon - Fri)

Website: https://bhutashah.com/