Patnaik S R

Practice Areas

S R Patnaik

Partner (Head- Taxation)

Taxation

S R Patnaik has more than 25 years of post-qualification experience specializing in various aspects of direct and indirect taxes, such as international tax, transfer pricing, corporate tax and GST. He is qualified both as a chartered accountant and lawyer. He has spoken at multiple conferences and seminars, both domestic and international, on various taxation matters. He has written a number of articles on several contentious issues dealing in the subject of taxation. He has expertise in various aspects of direct tax, such as international tax, transfer pricing, and corporate tax. He also has experience in various in-bound and out-bound M&A transactions. He also advises clients on the tax framework in India’s recently developed GIFT City. The clients with whom he has worked in the past operate across sectors such as including Aerospace, Automotive, Banking, Defense, Hospitality, Infrastructure, Insurance, ITES, Media & Entertainment, Mining & Metals, Oil & Gas, Pharmaceuticals, Private Equity, Real Estate, Retail & Consumer Goods, Roads & Highways, and Telecommunications. He has also advised international institutions and government agencies on various taxation aspects.

He has represented clients before multiple judicial fora including ITATs, High Courts and the Supreme Court and has also briefed Senior Counsels. He has received several accolades including being nominated as one of the leading Tax Lawyers for multiple years by Asia Law.

Professional Memberships

Bar Council of Delhi

Publications

• Livemint - Cyril Amarchand Mangaldas: Perspectives on Union Budget 2023-24 | Mint

• The Economic Times- Budget gives crypto some clarity but more importance to Digital Rupee

• Conventus Law- Budget gives crypto some clarity but more importance to Digital Rupee

• Moneycontrol- GST Council recommendations only have a persuasive value, clarifies Supreme Court

• Mint- Potential impact of the apex court’s GST Council ruling

• Lexology - Salary reimbursement of seconded employees not taxable in the hands of foreign company

• Lexology - Beneficial ownership test is not required under Indo-Mauritius tax treaty

• Legal Era - Metamorphosis of GST framework pertaining to Online Gaming

• Conventus Law- India – SC Delivers Two Landmark Judgments On Exemptions Claimed By Charitable Institutions

• Conventus Law- India – Refund Of Unutilised ITC Cannot Be Denied To Supplier Of Subcontracted Services

• Refund of Unutilised ITC cannot be Denied to Supplier of Subcontracted Services - https://tax.cyrilamarchandblogs.com/2022/11/refund-of-unutilised-itc-cannot-be-denied-to-supplier-of-subcontracted-services/

• SC delivers two landmark judgments on exemptions claimed by Charitable Institutions- https://tax.cyrilamarchandblogs.com/2022/11/refund-of-unutilised-itc-cannot-be-denied-to-supplier-of-subcontracted-services/

• Supreme Court holds that filing of declaration under Section 10B is mandatory- https://tax.cyrilamarchandblogs.com/2022/09/supreme-court-holds-that-filing-of-declaration-under-section-10b-is-mandatory/

• Supreme Court strikes down the old benami law as unconstitutional- https://tax.cyrilamarchandblogs.com/2022/09/supreme-court-strikes-down-the-old-benami-law-as-unconstitutional/

• Registration as a charitable institution cannot be made subject to conditions not prescribed under the IT Act- https://tax.cyrilamarchandblogs.com/2022/08/registration-as-a-charitable-institution-cannot-be-made-subject-to-conditions-not-prescribed-under-the-it-act/

• Karnataka High Court’s decision on GST levy provides a comfort to highway projects- https://tax.cyrilamarchandblogs.com/2022/08/karnataka-high-courts-decision-on-gst-levy-provides-a-comfort-to-highway-projects/

• SC Decision on Levy of GST on Ocean Freight May Act as Gamechanger- https://tax.cyrilamarchandblogs.com/2022/05/sc-decision-on-levy-of-gst-on-ocean-freight-may-act-as-gamechanger/

• Your Employee or Mine? – Determining Tax Implications on Hiring Foreign Employees from Related Foreign Entities-https://tax.cyrilamarchandblogs.com/2022/05/your-employee-or-mine-determining-tax-implications-on-hiring-foreign-employees-from-related-foreign-entities/

• Salary reimbursement of seconded employees not taxable in the hands of foreign company: Delhi ITAT- https://tax.cyrilamarchandblogs.com/2023/07/salary-reimbursement-of-seconded-employees-not-taxable-in-the-hands-of-foreign-company-delhi-itat/

• Cognizant’s High Court approved scheme of arrangement was held to be a colorable device by Chennai ITAT – https://tax.cyrilamarchandblogs.com/2023/09/cognizants-high-court-approved-scheme-of-arrangement-was-held-to-be-a-colorable-device-by-chennai-itat/

• CBDT exempts GIFT City aircraft leasing cos from withholding on dividend distributed inter se, but is it enough? – https://tax.cyrilamarchandblogs.com/2023/08/cbdt-exempts-gift-city-aircraft-leasing-cos-from-withholding-on-dividend-distributed-inter-se-but-is-it-enough/

• GST Council’s half century meeting & the inning ahead! – https://tax.cyrilamarchandblogs.com/2023/07/gst-councils-half-century-meeting-the-inning-ahead/

• Share subscription above fair market value would be subject to angel tax - https://tax.cyrilamarchandblogs.com/2023/07/share-subscription-above-fair-market-value-would-be-subject-to-angel-tax/

• Madras High Court takes taxpayer to task for mischief with costs – https://tax.cyrilamarchandblogs.com/2023/05/madras-high-court-takes-taxpayer-to-task-for-mischief-with-costs/

• A Court Approved Merger could still be Subject to Tax - https://tax.cyrilamarchandblogs.com/2023/05/a-court-approved-merger-could-still-be-subject-to-tax/

• Beneficial ownership test is not required under Indo-Mauritius tax treaty - https://tax.cyrilamarchandblogs.com/2023/01/beneficial-ownership-test-is-not-required-under-indo-mauritius-tax-treaty/