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Shivam Garg

Principal Associate in the Tax Practice at the Delhi NCR office of Cyril Amarchand Mangaldas. Shivam specialises in indirect tax advisory as well as litigation, and is also actively involved in analysing the impact of the Goods and Service Tax in India. He can be reached at shivam.garg@cyrilshroff.com

The Sacred Fortress of Privilege: Navigating the Scope of Client-Attorney Privilege

Summary: Client-attorney privilege in India is facing a moment of renewed scrutiny. As investigative agencies increasingly enter the professional space of advocates, the boundaries of this privilege are being tested like never before. Courts are now tasked with distinguishing between protected and unlawful conduct, while statutory safeguards under the Bharatiya Sakshya Adhiniyam, 2023 attempt to preserve the integrity of legal representation. This blog examines how recent jurisprudence is shaping the future of client confidentiality, raising urgent questions about privacy, procedural fairness, and the limits of investigative authority.Continue Reading The Sacred Fortress of Privilege: Navigating the Scope of Client-Attorney Privilege

Summary: This blog unpacks the sweeping GST rate rationalisations announced by the 56th GST Council meeting, covering key sectors such as food, healthcare, FMCG, agriculture, consumer goods, automobiles, infrastructure, and more. Beyond listing rate changes, we analyse their policy intent, business impact, and compliance challenges, from ITC reversals and refund reforms to supply chain recalibration and pricing strategies. For businesses, this is not just about new tax slabs but about aligning operations and strategy with a shifting indirect tax landscape.Continue Reading GST 2025: A Brave New Chapter in India’s Tax Reform

The Great Gamble: India’s Online Gaming Ban, the GST Battle, and What Lies Ahead

Summary: India’s online real-money gaming industry, once hailed as India’s next digital sunrise sector, now finds itself at a crossroads, caught between a sweeping ban under the Online Gaming Act, 2025, and a trillion plus rupee tax battle in the Supreme Court. The distinction between “games of chance” or “gambling” and the “games of skill”, established through years of litigation, now faces a knockout blow. A potential judicial somersault could result in retrospective GST demands, while the introduction of future prohibition could shut down future business models. This blog analyses the great gamble row unfolding, and what it means for founders, investors, and the future of India’s digital gaming industry.Continue Reading The Great Gamble: India’s Online Gaming Ban, the GST Battle, and What Lies Ahead

Treading a fine line: Extension is ultra-vires but valid?

Summary: This blog examines the ongoing judicial debate surrounding extensions of GST limitation periods in the wake of the pandemic and subsequent systemic challenges. It outlines the decision of the Hon’ble Madras High Court, which set aside Notification No. 56/2023 issued under Section 168A of the CGST Act, extending timelines for recovery orders for FY 2017-18, 2018-19, and 2019-20. The blog notes how this position differs from those adopted by the Hon’ble Guwahati, Telangana, and Bihar High Courts on the same matter, addresses the possible need for intervention by the Hon’ble Supreme Court, and outlines considerations for taxpayers.Continue Reading Treading a fine line: Extension is ultra-vires but valid?

Global Business, Local Tax: The Infosys GST Controversy and its Wider Implications

In an increasingly globalised economy, business activities extend beyond physical borders and traverse geographical boundaries, leading to varied tax implications due to outdated tax legislations that do not fully address these changes. In the service sector, tax obligations can arise even without traveling to different countries. A case in point is the recent incident of the revenue serving Infosys with a INR 32,403 crore (US$ 3.8 Billion) pre-show cause notice, which was later transferred to the Directorate General of GST Intelligence (“DGGI”) for further investigation. Prima facie, the tax assessment seemed not only excessive but also conceptually flawed, as it exceeded the annual profit declared by Infosys. The DGGI later withdrew the said notice. While the dust has settled on this high-stakes incident, the lessons may reverberate across India, particularly for multinational service providers. The questions raised during the investigation will have lasting significance and warrant consideration, extending beyond a single company or tax notice.Continue Reading Global Business, Local Tax: The Infosys GST Controversy and its Wider Implications

Time bound adjudication by revenue authorities: A distant dream or plausible reality?

In a tax system as vast and complex as India’s, time-bound adjudication is not merely a procedural ideal, it is also an essential pillar that promotes ease of doing business, upholds taxpayer trust, promotes administrative efficiency, and sustains the integrity of revenue collection. On the other hand, persistence of cases where adjudication lingers for a decade or more raises troubling questions.Continue Reading Time bound adjudication by revenue authorities: A distant dream or plausible reality?

From courtrooms to clicks: Rethinking why simple GST rectifications require Court intervention

The Goods and Services Tax (“GST”) regime was introduced with the promise of a seamless, technology-driven tax system aimed at reducing cascading effects and ensuring smooth compliance. However, after seven years of its introduction, businesses and taxpayers have found themselves burdened with the rigidity of a tax regime, which makes the subsequent correction of even the smallest of clerical errors in returns quite difficult and requires litigation to have them rectified. Continue Reading From courtrooms to clicks: Rethinking why simple GST rectifications require Court intervention

Revolutionising Import Clearance: The 2025 Customs (On-Arrival Movement for Storage and Clearance at Authorised Importer Premises) Regulations, 2025

Background

The government has implemented various measures to promote the growth of India’s manufacturing sector, such as the Production Linked Incentive schemes that were announced for the electronic industry under the Make in India initiative. It has also taken several steps to smoothen and fast track the import process, through digitalisation and faceless assessments. However, some issues remain.Continue Reading Revolutionising Import Clearance: The 2025 Customs (On-Arrival Movement for Storage and Clearance at Authorised Importer Premises) Regulations, 2025

GST liability on the benefits arising out of land: The conundrum continues

The applicability of Goods and Services Tax (“GST”) on various land-related rights has been a subject of ongoing debate, leading to uncertainty for businesses, developers, and policymakers. While the GST framework seeks to tax the supply of goods and services, transactions involving land and immovable property present unique challenges due to their distinct legal nature.Continue Reading GST liability on the benefits arising out of land: The conundrum continues

Legal debate at tipping point over Notification extending GST deadline

The legal validity of the contentious CGST Notification No. 56/2023 (“Notification“), is facing challenges across multiple High Courts in India. The Notification, issued by the Central Board of Indirect Taxes and Customs (CBIC), extended the timeline for passing orders under Section 73(10) of the Central Goods and Services Tax Act, 2017 (“CGST Act“) for financial years 2018-19 and 2019-20.Continue Reading Legal debate at tipping point over Notification extending GST deadline