Questions & Answers
Things clients ask us
We have tried to answer these the way we would in the room — directly, with the caveats where they matter, and without the boilerplate.
About the Firm
CNK RK & Co is a full-service chartered accountancy and advisory firm — but the comparison to a typical CA firm stops there. We have 54+ partners, 1,100+ professionals, and offices across Delhi, Gurgaon, Mumbai, Chennai, Vadodara, Ahmedabad, GIFT City, Bengaluru, Pune, Kolkata, Chandigarh, Dubai, and Abu Dhabi. Clients range from multinational subsidiaries and listed companies to PE-backed businesses, family offices, and first-generation founders. We are also part of the INAA Global Network, which gives us reach across 50+ countries when cross-border mandates require it. What genuinely sets us apart is the partner-led model — the partner who pitches your engagement stays on it.
In most large firms, the partner closes the deal and disappears. What the client actually gets is a manager and a team of juniors. At CNK RK, partner-led means the partner who pitches an engagement stays on it — reviewing files, signing off on advice, and available when a client needs a real conversation rather than a forwarded email. It also means advice that is commercially calibrated, not just technically correct. A technically correct answer that is commercially impractical is not much use to anyone.
Across the client base: manufacturing, financial services (NBFCs, AMCs, insurance companies), technology and SaaS, real estate and construction, media and entertainment, retail and e-commerce, healthcare, logistics, hospitality, and not-for-profit organisations. The breadth matters because tax and compliance problems rarely respect industry boundaries — a single real estate deal might have GST, FEMA, stamp duty, and TDS dimensions simultaneously. A team that has seen all of them is more useful than specialists who have never spoken to each other.
Direct Tax advisory and compliance, Indirect Tax (GST, Customs, FTP), Statutory and Internal Audit, Valuations, Business Advisory and Transaction Support, Governance Risk and Compliance, ESG reporting and assurance, Outsourced Finance and Accounting, IT audit and automation, CSR advisory, and dedicated practices for GIFT City (IFSC) and the UAE. Most engagements draw on more than one of these at once — which is why having them under one roof and one partner relationship matters.
The fastest route is the contact form on cnk-rk.co. You can also visit any of the offices across Delhi, Gurgaon, Mumbai, Chennai, Vadodara, Ahmedabad, GIFT City, Bengaluru, Pune, Kolkata, Chandigarh, Dubai, or Abu Dhabi. For career enquiries, write to careers@cnk-rk.co. We respond to all enquiries — and if the first person you speak to is not the right one for your matter, they will connect you to the partner who is.
Taxation
Everything from structuring a proposed transaction before it closes, to contesting an assessment order years after it did. The practice covers advisory opinions on complex tax issues, DTAA analysis, transaction structuring, ICDS implications, Safe Harbour Rules, POEM and BEPS advisory, Section 195 certification for foreign remittances, return filing and tax audits, Transfer Pricing documentation and APA negotiations, and representation before Income Tax authorities and the ITAT. The team also advises on the Income Tax Act 2025, which introduced significant changes to MAT, TDS frameworks, charitable trust taxation, and the search and seizure regime.
GST is deceptively complex for businesses with multi-state operations, mixed supply profiles, or significant import-export activity. The Indirect Tax team covers transaction advisory, SVB matters, end-to-end compliance (registrations, e-invoicing, return filing, refund applications), GST health checks, departmental audit support, and litigation before GST authorities and the DGFT. Automated compliance solutions are built where manual processes have become a liability. Customs and Foreign Trade Policy advisory is part of the same practice — and often the same conversation.
Transfer Pricing is one of those areas where getting it wrong is expensive and getting it right early is almost always cheaper. The firm handles benchmarking studies, Master File and Local File documentation, Country-by-Country Reporting, Safe Harbour Rule analysis, APA filings and negotiations, and representation in TP assessments and appeals. The practice is aligned with OECD BEPS standards and the Multilateral Instrument. Engagements have covered intra-group services, IP licensing, financial transactions, and complex intercompany supply chains.
The Income Tax Act 2025 replaced a 65-year-old law that had been amended nearly 4,000 times. It is not a cosmetic clean-up — it introduces a restructured framework for charitable trusts, changes to MAT, new TDS provisions, significantly expanded search and survey powers, and a transition mechanism running two parallel regimes simultaneously for an overlap period. The firm has been tracking this from the draft stage and advises businesses and individuals on what changes, what the transition requires, and where planning opportunities exist. The full breakdown is on The Advantage.
GAAR has been in force since FY 2017-18, and the tax department has grown more comfortable invoking it — particularly in restructuring and treaty-benefit contexts. The test goes to the main purpose of an arrangement: if the primary objective is a tax benefit with no meaningful commercial substance, the arrangement can be disregarded or recharacterised. CNK RK advises clients on GAAR exposure during transaction structuring — before a deal closes, not after. If you are looking at a structure and wondering whether it will survive GAAR scrutiny, that is a conversation worth having early.
Audit & Assurance
Statutory Audits under various Indian statutes, Internal Audits, Management Audits, GRC Audits, Special Audits and Investigations, IT Systems Audits, Concurrent Audits, compliance audits on behalf of regulators (SEBI, RBI, AMFI), and ISAE 3000-based assurance for ESG and BRSR reporting. The firm also assists multinational subsidiaries with foreign group reporting packs and IFRS to Indian GAAP reconciliations.
Risk-based, with genuine partner involvement throughout. An audit that identifies risks only at the end of the process is too slow to be useful. Each engagement is planned around the specific risks of that business — industry, scale, complexity of internal controls, regulatory environment — with continuous review rather than a single final sweep. Findings are backed by data, written without diplomatic vagueness, and recommendations are grounded in what is operationally feasible. A long management letter that nobody acts on is not a good audit.
BRSR is mandatory for the top 1,000 listed companies, and the numbers need to be defensible — this is not a checkbox exercise. The ESG practice starts with the underlying data architecture: building the systems that collect and validate ESG data at source, before anyone writes a report. The team then designs the governance structure for reporting, maps disclosures to SEBI's BRSR principles, and provides ISAE 3000-based assurance on the output. The team includes environmental consultants. Supply chain ESG validation is also in scope, increasingly required by institutional investors and large export customers.
Advisory
End-to-end transaction support — structure conceptualisation, commercial negotiation, deal execution, review of transaction documents, financial and tax due diligence, and post-transaction implementation. The team has worked on the buy side and the sell side: PE acquisitions, founder liquidity events, strategic M&A, and family business stake transfers. Internal restructuring mandates — mergers, demergers, slump sales, buybacks, capital reductions, ESOP design — and succession planning for promoter groups are also within scope. The approach is multi-disciplinary: tax, legal, and commercial do not move in isolation.
A slump sale — the transfer of an entire undertaking for a lump-sum — is taxed on the difference between the consideration and the net worth of the undertaking, computed under a specific formula. The consideration must meet the Rule 11UAE floor and be certified by a Chartered Accountant in Form 3CEA. Where related parties are involved, GAAR scrutiny is a real risk if commercial substance cannot be demonstrated. CNK RK handles the valuation, structuring, certification, and filing — and we are direct with clients when a proposed structure creates more exposure than it removes. The firm's detailed write-up on slump sale mechanics is on The Advantage.
Business valuations for fundraising rounds, FEMA-mandated fair value certifications for FDI and ODI transactions, slump sale valuations with Form 3CEA certification, ESOP design and annual valuation, M&A deal support, and independent fair value opinions for litigation or regulatory purposes. Methodologies include DCF, Comparable Company Analysis, Net Asset Value, and Royalty Relief — the right one depends on the asset and the purpose. The team has valued businesses in technology, media, financial services, healthcare, and real estate. A valuation is only as useful as its defensibility, and we build for that from the start.
Restructuring — mergers, demergers, slump sales, buybacks, capital reductions — requires the tax, legal, and commercial dimensions to move together. We bring a cross-disciplinary team to these mandates. Engagements have included internal restructuring for promoter families ahead of succession events, ESOP restructuring for pre-IPO companies, NCLT-sanctioned demergers, and sale of undertakings to PE acquirers. The approach is to be direct about the real cost of a proposed structure in tax, regulatory friction, and time — before anyone commits to it. Structures that look clean on a whiteboard can look very different when you run them through the actual regulatory steps.
CSR under the Companies Act is not optional above the prescribed thresholds — and the penalties for non-compliance, or for spending that does not qualify as a CSR activity under the Act, are real. CNK RK helps companies design a framework that is both compliant and strategically coherent, develop the annual action plan, incorporate and register Section 8 companies or trusts where a separate CSR arm is needed, document arrangements with implementing partners, monitor fund utilisation, and produce the statutory report. Impact assessment mandates — required for spends above ₹1 crore on a single project — are also in scope.
Regulatory & FEMA
FEMA is an area where the law itself is not complicated, but the consequences of getting it wrong are serious and the RBI's expectations on documentation and timelines are unforgiving. Services cover inbound FDI structuring, outbound ODI compliance, round-tripping risk, repatriation of funds, intercompany loan structures, POEM implications for holding companies, and representation before the Enforcement Directorate. The firm also handles the FEMA dimension of larger transactions — Delaware Flips, PE investments, cross-border M&A, and group restructurings — where exchange control is one piece of a more complex puzzle.
The GRC practice handles Internal Audits, Management Audits, Enterprise Risk Management design and implementation, Internal Financial Controls documentation and testing, SOP development, fraud vulnerability assessments, forensic investigations, and compliance reviews under FEMA, SEBI, IRDA, and RBI regulations. The team also conducts audits on behalf of statutory bodies including SEBI, RBI, and AMFI. The focus is on findings that are actionable and supported by data — not on producing long reports that sit on a shelf.
The regulatory incentives for an IFSC unit are genuinely compelling — near-zero effective tax for the first ten years, exemptions from several domestic indirect taxes, and a more flexible regulatory environment for financial services businesses. The GIFT City practice covers feasibility assessment, entity selection and IFSCA registration, direct and indirect tax advisory, Transfer Pricing, concurrent audits, IFC framework design, and virtual office support for smaller businesses at the initial stage. The answer is not always yes to a GIFT City unit — structure and timing matter significantly, and a feasibility conversation should come before a commitment.
Outsourcing
Accounting and financial statement preparation, accounts payable and receivable, payroll with TDS processing, vendor payment and TCS compliance, GST-compliant invoicing, fixed asset records, and transaction processing for FIIs, SPVs, and liaison offices of foreign entities in India. The value is in having a finance function that is audit-ready at all times, with compliance calendars tracked proactively rather than reactively. The practice also supports international CPA firms through a dedicated outsourcing vertical for their India-facing work.
General IT Controls and Application Controls assurance, data migration audits, VAPT (Vulnerability Assessment and Penetration Testing), digital forensics, ERP implementation support and post-implementation review, workflow automation for approval processes, Business Intelligence dashboard design, and regulatory IT audits. The team supports compliance with SOC Type 1 and 2, SOX, HIPAA, and PCI-DSS frameworks. Audit data analytics — using actual transaction data to drive findings rather than sampling alone — is a core part of how the team conducts both IT and financial audits.
International
Most foreign clients come in asking how to register a company. That is usually the wrong place to start. The real question is what structure makes sense for what you are trying to do in India. A Liaison Office, Branch Office, Wholly Owned Subsidiary, and Joint Venture each have very different regulatory, tax, and operational profiles — and the wrong choice early creates costs that are difficult to reverse. CNK RK works through entity selection first, then handles setup, FEMA filings, RBI approvals, tax registrations, Transfer Pricing, and ongoing compliance from one team. The firm's India entry guide is also on The Advantage if you want to read before you call.
The Delaware Flip is a corporate restructuring where an Indian-founded company places a Delaware C-Corp as the parent entity — primarily to access US venture capital. It sounds straightforward. It is not. The challenges include FEMA round-tripping restrictions (significantly tightened by the 2019 FEMA modifications), capital gains tax on IP and share transfer, and POEM risk — where the Delaware entity may still be treated as tax-resident in India based on where decisions are actually being made. Whether to flip depends on the stage of the business, investor requirements, and the founders' long-term intentions. The firm has seen cases where it was clearly the right call and others where the regulatory cost outweighed the capital benefit. The full analysis is on The Advantage.
The Dubai and Abu Dhabi offices are a functioning practice, not a flag on a map. UAE Corporate Tax was introduced in June 2023 and is still a moving target in terms of ministerial decisions and FTA guidance. The team handles UAE CT compliance and planning, VAT, Transfer Pricing, Economic Substance Regulations, audit and assurance, company incorporations, financial due diligence, valuations, M&A advisory, and ESG assurance. The practice is also used by Indian promoter groups and NRIs structuring investments and holdcos between India and the UAE — the India-UAE DTAA is one of the more navigated treaties in the firm's cross-border practice.
This is one of the most time-sensitive issues in the practice, and one of the most underestimated. The residency thresholds under the Income Tax Act — 60 days, 120 days, 182 days — are not flexible. Once you cross the relevant threshold in a financial year, you are a Resident for that year. A full Resident is taxable on global income. Even an RNOR, while better protected, carries disclosure obligations most NRIs are unprepared for. The critical constraint: this cannot be corrected after 31 March. CNK RK advises NRIs, expats in the Middle East, and returning Indians on advance planning, DTAA relief, global income disclosure, and the documentation required to defend a non-resident position if it is ever questioned. The firm has published a residency self-assessment tool for a preliminary read.
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