Prevention before defence
Most exposure is created years before a notice arrives: in a structure, a valuation, a filing. We recognise the patterns that draw attention because we used to act on them.
Tax · Structuring · Advisory
Know the groundbeforeyou move.
Tax, regulatory, corporate and forensic advisory for corporates, promoters, family offices and institutions, grounded in decades of specialist practice and the judgment that only years of it can build.
ChennaiBangaloreKozhikodeKolkataDelhiMumbaiSuratChandigarhDubai
ScrollLed by former officers of the Indian Revenue Service.
The partners between them carry decades of service in tax, regulatory and commercial law: long enough to have seen provisions drafted, amended, litigated and finally settled, and to know which arguments have already been tried, which still hold, and which were never going to survive contact with a tribunal.
That depth is not a line in our biographies; it is the method of the practice. Long experience tells you where a position is genuinely strong, where it is merely arguable, and when the quieter course is the better one. It is judgment that cannot be researched, only accumulated.
We read a file the way it was built
An assessment order is a construction. Having built them, we can see which findings carry weight, which are padding, and where the record was never properly made at all.
Judgment about escalation
When to close a matter at assessment and when to carry it through appeal is the hardest call in a proceeding. We have seen both outcomes from the other chair.
We know the record that will be wanted
What has to be produced, in what form and by when: assembled before it is called for, rather than gathered under pressure once it has been.
We know what a submission must answer
Departmental matters turn on specific, documented responses to specific findings. We draft to the point that decides the case rather than around it.
Perspective on what is actually new
Much of what looks novel is a settled question in different clothing. Long exposure tells you which is which, and spares the cost of arguing a point already decided.
Procedure, treated as substance
Limitation, jurisdiction, sanction, natural justice: procedure decides more matters than merit does. We know that procedure from having applied it.
Exposure priced honestly
Having sat in adjudication, we know which positions survive scrutiny and which will not. Our assessment of your risk is a forecast, not an encouragement.
Diagnostic before prescriptive. Verified before advanced.
Guardian Strategies brings tax, corporate, regulatory and forensic capability together under a single mandate. We advise businesses, promoters, family offices and institutions on the decisions that carry weight: structuring capital, entering new jurisdictions, responding to regulators, and building the compliance architecture that keeps all of it durable. note: Our work is diagnostic before it is prescriptive. We establish the facts, verify them at source, quantify the exposure, and only then recommend a course. What we produce is built for your organisation and its circumstances, never adapted from a template, and never advanced unless the law supports it.
Our work is diagnostic before it is prescriptive. We establish the facts, verify them at source, quantify the exposure, and only then recommend a course. What we produce is built for your organisation and its circumstances, never adapted from a template, and never advanced unless the law supports it.
Continuity of advisers
The same team holds your context from the first question to the final resolution. No re-briefing between matters.
Technology-enabled
Research infrastructure, document automation and digital forensic capability, so people spend their time on judgment.
Multi-disciplinary depth
Tax, corporate, FEMA and forensic mandates handled within the firm, so cross-cutting matters move as one coordinated workstream.
Two jurisdictions, one opinion
Where a structure touches India and the UAE, the position is reconciled across both before it is advanced in either.
Confidentiality by default
Engagements scoped, documented and protected, and kept that way long after the mandate closes.
Source-verified analysis
Every position traced to the governing provision, circular or ruling, confirmed against the original record, not a summary of it.
How the firm works
1
Diagnose
Establish the facts and quantify exposure before any position is taken.
2
Structure
Design the arrangement that meets the objective inside the regulatory perimeter.
3
Implement
Execute filings, approvals, documentation and submissions end to end.
4
Sustain
Track regulatory change and keep the structure current as conditions shift.
Twelve practice areas, one conversation.
Direct and indirect tax, enforcement, cross-border capital, regulatory, corporate, trusts, property, forensic audit, dispute support, intellectual property and representation. Open any area to see its scope.
Income-tax planning, transfer pricing and treaty positions, TDS and return filing, prepared and presented through assessment and appeal, with litigation support to counsel before the High Courts and the Supreme Court.
GST registration, returns, reconciliation and input tax credit management; customs duty assessment, import-export documentation and FTP compliance, with audit representation, departmental proceedings, and litigation support to counsel before the appellate tribunals, the High Courts and the Supreme Court.
Assessing exposure before a proceeding is initiated, structuring the response to attachment and confiscation, and building the anti-money-laundering architecture that keeps an organisation defensible.
Securing licences and approvals across banking, NBFCs, payment systems and foreign exchange, presenting responses during inquiries, and holding compliance steady as regulation changes.
Entity structuring, mergers and acquisitions, governance frameworks and statutory compliance, with advisory support through NCLT proceedings and insolvency under the IBC.
Trust operations, compliances, filings and approvals for family, charitable, religious and institutional vehicles, including the conversion and merger of trusts, the approvals each requires, and the succession planning that follows from them.
Title due diligence, government approvals and full RERA compliance for developers, buyers, investors and agents, with documentation, transaction support and advisory across the whole project lifecycle, from land appraisal to handover.
Forensic investigation including digital forensics and fraud vulnerability assessment: testing where an organisation is exposed before anything goes wrong, and delivering evidence-grade reporting and expert input where it already has.
Mediation, arbitration and commercial negotiation: case strategy, financial analysis, valuation of claims, documentation and expert input, structured to resolve matters without dismantling the relationship behind them.
Trademark, copyright and patent registration and prosecution across classes and jurisdictions, with Customs IPR recordal at SIIB against infringing imports, and advisory on licensing, royalties and portfolio strategy.
Advisory on statutory rights and obligations, and the preparation and presentation of representations before regulatory and departmental authorities, with briefing and coordination alongside counsel where a matter proceeds to court.
Inbound (FDI) and outbound (ODI) investment across debt (ECB) and non-debt instruments: structuring, due diligence and approvals, then continuing FEMA and RBI compliance.
A dedicated advisory team, on a fixed monthly retainer.
One team. One fee. Full scope.No itemised billing. No hidden costs. Scoped to mandate and complexity.
Built for businesses, promoters, high net-worth individuals and institutions that need sustained, proactive advisory support rather than transaction-by-transaction billing. For a fixed monthly fee, clients receive the full depth of the practice as a dedicated team, from day-to-day consultation through to board-level strategy, without the friction of fresh instructions each time a question arises.
Consultation
Unlimited access to senior advisers on day-to-day decisions.
Planning and structuring
Structuring transactions and stress-testing commercial plans.
Risk assessment
Tax and regulatory exposure across operations and transactions.
Risk identification
Early warning on regulatory change and enforcement trends.
Prevention strategy
Frameworks and structures that close identified gaps.
Matter handling
From notice through assessment to resolution.
Tailored solutions
Built for your organisation and its facts, never a template.
Long-horizon strategy
Positioning, dispute avoidance and governance architecture.
Why it works
A retainer replaces a fragmented, reactive approach with a single, deeply embedded advisory team, available from the first question to the final resolution, at a predictable monthly cost. Every advisory need within scope, nothing carved out.
- Efficient costA full advisory team for a fraction of in-house overhead.
- Proactive, not reactiveExposure closed before it escalates.
- Continuity of contextSame team, same history, every matter.
- Predictable budgetingA fixed fee, no surprise invoices.
- End-to-end coverageConsultation to resolution, in one place.
Who we work with
Corporates and groups
Structuring, governance, direct and indirect tax, and regulatory compliance across group entities.
Promoters and family offices
Holding structures, succession planning, trust taxation, and the enforcement risk between them.
High net-worth individuals
Direct taxation, trust structures, residency questions and cross-border asset positions.
Foreign investors
India entry and FDI structuring, FEMA and RBI approvals, and continuing compliance.
The partners
Each partner carries a former chair in the Indian Revenue Service or a specialist practice built alongside it. Between them the practice covers tax, enforcement, cross-border capital, corporate and forensic work in both jurisdictions.
P. S. Sivasankaran is the Founding Partner of Guardian Strategies LLP. He served as a career civil servant of the Government of India for over 20 years before taking voluntary retirement in August 2024 to pursue his entrepreneurial interests.
Professional Career
Having successfully cleared the Indian Civil Services Examination on his first attempt, he joined the Ministry of Defence in 2003 and subsequently joined the Income Tax Department (Indian Revenue Service) in 2005. Between 2007 and 2010, he handled tax administration and investigation of tax crimes in the Mumbai region.
In 2011, he joined the Department of Revenue, Ministry of Finance, Government of India, as Under Secretary in the Foreign Tax and Tax Research Division. In this role, he worked on policy matters relating to international taxation, negotiated tax treaties, coordinated cross-border investigations, and handled international tax matters involving multilateral organisations including the OECD, Global Forum, United Nations and World Bank.
OECD Experience
On special leave from the Government of India, he joined the Organisation for Economic Co-operation and Development (OECD), an international organisation headquartered in Paris, France, in 2014 as a Tax Policy Advisor. He contributed to the development and implementation of international standards on tax transparency, including the Common Reporting Standard. He conducted peer reviews of several jurisdictions and provided technical assistance to developing countries on capacity building relating to tax transparency standards and tax administration.
Senior Tax Administration Roles
He returned to India in September 2019 and served as Additional Commissioner of Income Tax, handling international taxation matters in Chennai, until October 2020. He subsequently served as Additional Director of Income Tax (Investigation) until June 2023, during which several high-profile investigations in South India were conducted under his supervision.
On promotion, he was posted as Commissioner of Income Tax (Appeals), where he adjudicated appeals arising from serious tax crime cases.
Awards & Recognition
He received the National Award from the Election Commission of India for exemplary work during the State Assembly Elections, 2021. He was also a recipient of the Finance Minister's Award, 2022, for his contribution to the Department, as well as an award from the Principal Chief Commissioner of Income Tax, Tamil Nadu and Puducherry, for outstanding work during 2022–23.
Practice & Advisory Experience
At Guardian Strategies LLP, he advises clients on taxation, money laundering, foreign exchange, Goods and Services Tax, company law and other regulatory matters. His expertise also extends to stressed asset management, including the turnaround of insolvent companies.
GUARDIAN STRATEGIES LLP
While establishing a venture capital/private equity fund focused on DeepTech and FinTech, he has also bootstrapped and mentored start-ups, guiding them through seed-stage growth.
Corporate & International Experience
Sivasankaran holds directorships in 10 entities across education, real estate, consulting, travel and advertising. He also founded a corporate and tax advisory firm in Dubai focusing on cross-border investment advisory, structuring, mergers and acquisitions, and tax management.
Education & Professional Qualifications
- B.Tech. in Engineering, Madras Institute of Technology, Chennai
- Master's in Taxation and Business Laws, NALSAR University of Law, Hyderabad
- Master's in Economics, Madurai Kamaraj University
- Executive Education Certificate, Indian School of Business
- Higher Diploma in Software Engineering
- Certificate courses in International Taxation and Cyber Forensics
Languages & Interests
His interests include travel, hiking, football and chess. He is fluent in English, Tamil and Hindi and has basic working knowledge of French.
- Based in
- Chennai
- Admitted
- B.Tech. (Madras Institute of Technology), Master's in Taxation and Business Laws (NALSAR University of Law), Master's in Economics (Madurai Kamaraj University)
- Languages
- English, Tamil, Hindi, basic French
- Write to
- sivasankaran@guardianlegal.org
Ashish Heliwal is a finance, tax and legal professional with over two decades of experience across taxation, international tax policy, transfer pricing, finance and financial analysis.
Professional Experience
A significant part of his career has been with the Income Tax Department, Government of India, where he handled complex taxation matters with particular focus on International Taxation and Transfer Pricing. His international tax and transfer pricing experience includes work on Advance Pricing Agreements (APAs), Mutual Agreement Procedures (MAPs), and Double Taxation Avoidance Agreements (DTAAs), including engagement and negotiations with Competent Authorities of other jurisdictions. He also served as a Tax Advisor to the Republic of Seychelles, advising on transfer pricing, taxation and related policy matters.
Qualifications
His multidisciplinary professional qualifications include Chartered Accountancy (CA), Chartered Financial Analyst (CFA), Bachelor of Laws (LL.B.) and Certified Associate of the Indian Institute of Bankers (CAIIB). This combination of qualifications enables him to approach complex business matters from the perspectives of accountancy, finance, investment analysis, law and banking.
Advisory Approach
He believes that effective advisory solutions require an understanding of the underlying commercial objective, followed by an integrated evaluation of the tax, legal, financial and regulatory implications.
Areas of Professional Focus
- International Taxation & Transfer Pricing
- Cross-Border Tax & Transaction Structuring
- Advance Pricing Agreements (APA), Mutual Agreement Procedures (MAP) & Tax Treaty Matters
- Corporate & Financial Advisory
- Mergers & Acquisitions (M&A;) and Transaction Advisory
- FEMA & Cross-Border Investments
- Family Wealth, Estate & Succession Planning
- Corporate Governance & Strategic Advisory
Advisory Perspective
He is particularly focused on advising businesses, promoters, investors and families on complex situations where tax, law, finance and strategy intersect. At Keystone Strategic Consultants LLC, he brings an integrated perspective to matters involving international taxation, transactions, corporate finance, cross-border structuring, governance, and wealth and succession planning.
- Based in
- India
- Admitted
- CA, CFA, LL.B., CAIIB
- Languages
- English
Sunil Mathur is an engineer from Birla Institute of Technology and Science (BITS), Pilani, and holds an MBA from the University of Rajasthan. He belongs to the 1988 batch of the Indian Revenue Service (IRS) and joined the Income Tax Department in January 1989.
Professional Career
He retired as Principal Chief Commissioner of Income Tax, Tamil Nadu and Puducherry, in October 2024, after a distinguished career spanning over 36 years in the Income Tax Department. During his long career, he served in various capacities across India, gaining extensive experience in Direct Tax Laws, PMLA, FEMA, the Black Money Act, the Prohibition of Benami Property Transactions Act, and the Companies Act, among others. He served in the Investigation Wing of the Income Tax Department for nearly 15 years, gaining extensive experience in search and seizure operations, investigation of complex financial matters and related assessments.
Education & Professional Development
He holds a Master's degree in Economics from the University of Rajasthan. He also completed a one-year Master in Public Management (MPM) programme at the Lee Kuan Yew School of Public Policy, National University of Singapore, including a semester at the John F. Kennedy School of Government, Harvard University, Boston, USA.
Areas of Expertise
His professional experience encompasses direct taxation, financial investigation, search and seizure proceedings, tax assessments, money laundering, foreign exchange regulations, benami property matters, black money regulations and corporate law. At Keystone Strategic Consultants LLC, he brings his extensive experience in tax administration, investigation and economic and regulatory laws to provide strategic advisory support on complex tax, financial and regulatory matters.
- Based in
- India
- Admitted
- Indian Revenue Service, 1988 batch
- Languages
- English
Mr. Dileep Kumar is from Banda, Uttar Pradesh, where he completed his initial schooling. He has an excellent academic record and secured 14th rank in the Class 12 examination across the state.
Education
He completed his Electronics Engineering from Motilal Nehru Regional Engineering College, Allahabad (now MNNIT) and subsequently obtained a Bachelor of Laws (LL.B.) from the University of Mumbai.
Professional Career
He began his professional career as a Research Engineer at the Centre for Development of Telematics (C-DOT) in August 1999. He subsequently secured All India Rank 1 in the Engineering Services Examination conducted by UPSC and joined the Indian Telecommunications Service (ITS) in April 2002. He later cleared the Civil Services Examination and joined the Indian Revenue Service (IRS) in August 2005. During training at the National Academy of Direct Taxes (NADT), Nagpur, he was awarded a Gold Medal and adjudged Best Probationer.
Experience in Income Tax Administration
- He served in the Income Tax Department from 2005 to 2023, working in Ahmedabad, Mumbai and Surat, before taking voluntary retirement in May 2023 to pursue his entrepreneurial interests.
- His experience covered International Taxation, Transfer Pricing, Advance Pricing Agreements (APA), Investigation, Assessment, TDS and Tax Administration.
- While in service, he also completed his LL.B. from the University of Mumbai.
Professional Interests
Following his voluntary retirement, he has pursued his entrepreneurial interests. He has a keen interest in sports and plays badminton and tennis. He also enjoys travelling and interacting with people. At Keystone Strategic Consultants LLC, he brings his experience across taxation, international tax, transfer pricing, investigation and administration, together with his engineering and legal background, to support clients on complex tax and business matters.
- Based in
- India
- Admitted
- Indian Revenue Service, LL.B. (University of Mumbai)
- Languages
- English
T. Muralidharan is a senior civil servant of the Indian Revenue Service with nearly four decades of experience across diverse offices of the Government of India. Over the course of his career, he has served in the Ministry of External Affairs, the Office of the Accountant General (Audit), and the Income Tax Department, holding positions of increasing responsibility. Professional Profile He brings a combination of administrative experience, financial acumen and investigative expertise developed through extensive public service.
Core Expertise
- Tax investigation and enforcement, with eleven years spent in the Investigation Division of the Income Tax Department.
- Direct taxation, assessment, and administration across the full spectrum of Income Tax functions.
- Government audit and public accountability, gained in the Office of the Accountant General (Audit).
- Public administration and inter-departmental coordination, including service with the Ministry of External Affairs.
- Regulatory compliance, financial scrutiny, and the interpretation and application of statutory frameworks.
Professional Experience
Government of India: Nearly four decades of service in a range of offices and capacities, building institutional knowledge of India's financial and revenue machinery. Income Tax Department – Investigation Division: More than a decade devoted to tax investigation, including detection of tax evasion, examination of complex financial records and enquiries under direct tax laws. Office of the Accountant General (Audit): Contributed to the audit and oversight of government finances, strengthening expertise in public accountability and financial control. Ministry of External Affairs: Served the Government in matters of external affairs, broadening administrative experience beyond the revenue domain.
Advisory Perspective
At Guardian Strategies LLP, his experience provides clients with a first-hand understanding of tax and audit administration in India, particularly in matters involving tax scrutiny, investigation and dispute, with a focus on procedure, evidence, enforcement, compliance and probity.
- Based in
- India
- Admitted
- Indian Revenue Service
- Languages
- English
Sanil Sivadas is a former officer of the Income Tax Department of India who retired as Deputy Commissioner of Income Tax. He spent 17 years in the Investigation Wing. His service was recognised with the Principal Chief Commissioner of Income Tax's Award for Meritorious Service in 2024. He holds a B.A. in History and Economics from Malabar Christian College, Calicut, and an LL.B. from Government Law College, Calicut.
- Based in
- Kozhikode, Kerala
- Admitted
- Indian Revenue Service
- Languages
- English
- Write to
- sanilsivadas@gmail.com
Nine offices. Two countries. One practice.
Nine branches across India and the United Arab Emirates, reached through one practice rather than nine switchboards.
- ChennaiHeadquarters, Tamilnadu office — open the enquiry form with this office selected
- BangaloreKarnataka office — open the enquiry form with this office selected
- KozhikodeKerala office — open the enquiry form with this office selected
- KolkataWest Bengal office — open the enquiry form with this office selected
- DelhiNorth India, NCR office — open the enquiry form with this office selected
- MumbaiMaharashtra office — open the enquiry form with this office selected
- SuratGujarat office — open the enquiry form with this office selected
- ChandigarhPunjab and Haryana office — open the enquiry form with this office selected
- DubaiUnited Arab Emirates office — open the enquiry form with this office selected
Begin a conversation
Whatever the question, one conversation reaches the whole practice.
My matter starts with
Choose one and we will tell you where it lands in the practice, and who will pick it up.
P. S. Sivasankaran
Founder Partner, formerly Indian Revenue Service
A partner replies within one business day. The first conversation carries no obligation.
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This website is a general firm profile and is not tax, legal or investment advice. Engagement with Guardian Strategies LLP is subject to a formal letter of engagement, applicable professional standards, and conflict-of-interest checks.