IT & Software Companies

You write software.
We protect the margin.

For Indian SaaS startups, software exporters, and IT services companies billing US/EU clients — we manage the export benefits, transfer pricing, GST refunds, and tax planning specific to your business model. The work that decides whether your 70% gross margin actually reaches your bank.

Active IT/SaaS Retainers40+ Companies
GST Refunds Recovered₹50 Cr+ in 3 Years
SEZ Units Set Up4 in Last 24 Months
TP Studies CompletedUS · UK · SG · NL
Who This Page Is For

If your invoices are mostly in dollars — keep reading.

01

The Indian SaaS Startup

80%+ international revenue, billing US/EU customers in USD/EUR. Need export documentation, GST refunds, transfer pricing for inter-company services, and tax planning for the long haul.

02

The IT Services Exporter

Bench rates to US clients, MSA-based contracts, monthly billing. Need clean LUT-based exports, predictable refund cycles, and TDS optimisation on US client withholdings.

03

The Founder Considering SEZ

Considering SEZ unit setup vs continuing in DTA. The difference is 5-10% of revenue compounded over 10 years — the math is worth doing right before signing the lease.

04

The Company With Stuck GST Refunds

Lakhs sitting in unclaimed ITC, RFD-01 applications hanging with deficiency memos, GSTR-2A mismatches, LUT renewal delays. We recover the money sitting with the government.

The Anchor Decision

Where you set up your delivery entity decides 30-40% of your tax bill.

The four-way choice — DTA, SEZ, STPI, foreign subsidiary — is not a "later" decision. The benefits are tied to where the unit is incorporated and operates from Day 1. Move later, miss eligibility. For a 30-person SaaS company with 100% US revenue, this single decision can be ₹4 Cr+ over 10 years.

ParameterDTA (Domestic)SEZ UnitSTPI UnitForeign Subsidiary
Income tax rate22% under 115BAA22% — 10A/10B benefits expiredLocal (US 21%, Singapore 17%) + India tax on dividend
GST on exportZero rated, refund of ITC via RFD-01Zero rated, refund of ITCN/A (foreign jurisdiction)
Setup cost & timelineHigher — SEZ developer space + approvals (3-4 mo)Medium — STPI registration + bond executionHighest — local incorporation + FEMA ODI
Operational restrictionsMust operate from SEZ premises onlyBonded premises, customs controlLocal employment laws, transfer pricing for India ops
Repatriation of profitsDividend / royalty / fees — withholding tax + Indian tax
Compliance burdenStandard corporate complianceSEZ-specific filings + customs reportsSTPI quarterly + annual + softexHighest — two-country compliance
Best forHybrid revenue (domestic + export), small teamsExport with operational simplicityUS sales presence, IP held abroad, large scale

Three real situations where the wrong call cost crores.

!

30-person SaaS, 100% US revenue, stayed DTA. Eligible for SEZ from incorporation but no one ran the math at Day 1. Lost 9 years of Section 10AA benefit eligibility = ₹4 Cr+ in cumulative tax savings on a profitable trajectory. SEZ benefit cannot be claimed retroactively.

Cost: ~₹4 Cr+ over 10 years
!

SaaS founder set up Delaware C-Corp with India team — no TP study. Three years of inter-company billing without TP documentation. Notice from Indian tax authority on AY 2022-23. Reconstructed TP after the fact = panic, audit cycles, expensive.

Cost: ₹38 L tax + 5 mo of distraction
!

40-person company, ₹2.8 Cr stuck in GST refunds. Previous CA filed RFD-01s but never followed up on deficiency memos. ITC sat unclaimed for 18 months. By the time the founder noticed, two RFD-01s had crossed time-bar and partial credit was lost.

Cost: ₹2.4 Cr recovered, ~₹40 L lost

The two-minute decision shortcut.

  • 100% export, > 25 employees, profitable trajectory, scaling 5+ yearsSEZ Unit.
  • Mixed export + domestic revenue, small teamDTA.
  • Need US sales entity, holding global IPDTA + Foreign Subsidiary.
  • Single-founder consulting, < ₹1 Cr revenueDTA. Don't over-engineer.

If you are at incorporation, or scaling past 20 people with mostly export revenue — book a structuring call → The math is concrete. The compounding effect over 10 years is concrete.

Services

The full IT/SaaS compliance & planning stack.

Every line item that touches a software company file — domestic or export — handled by the same team.

SEZ Unit Setup & AdvisoryEligibility assessment, SEZ developer co-ordination, Letter of Approval (LoA), bond execution, customs registration. 4 SEZ unit setups in last 24 months.
Section 10AA ComputationYear-wise deduction calculation, separate book-keeping, MAT applicability under 115JB, transition planning post-tax-holiday.
Transfer Pricing — Form 3CEBTP study with TNMM / CUP / Cost-plus benchmarking, master file (where applicable), CbC reporting (large groups), defended at TPO scrutiny.
GST Refund Filings (RFD-01)Monthly refund applications, ITC tracking, deficiency memo response, escalation. ₹50 Cr+ recovered for clients in last 3 years — never let your money sit with the government.
LUT Filings & RenewalLetter of Undertaking annual filing, conditions monitoring, replacement of LUT with bond if conditions breached.
Reverse Charge GST on ImportsRCM on foreign software/SaaS subscriptions, ITC eligibility, foreign service provider OIDAR registration co-ordination.
Foreign Tax Credit (DTAA)Form 67, TRC co-ordination, foreign withholding recovery for India-incorporated companies billing US clients with WHT deducted.
Forex Revenue Recognition (Ind AS 21)Multi-currency invoicing, exchange differences, monetary vs non-monetary translation, hedging accounting (Ind AS 109 for relevant entities).
Tax Audit + ITR-644AB tax audit, Form 3CD with detailed clause-wise disclosures, ITR-6 with international transactions schedule.
Statutory Audit + Companies ActAudit under Companies Act, AOC-4, MGT-7, board minutes, AGM, all ROC filings on calendar.
SOC 2 / ISO 27001 Financial Controls AuditFor SaaS companies pursuing enterprise contracts — financial controls, change management, access reviews mapped to your audit framework.
Retainership for IT CompaniesMonthly bookkeeping, GST, TDS, payroll, ROC, GST refunds — single retainer, ecosystem-ready team.
How We Work

Built for the speed your business runs at.

01

Discovery + Revenue Mix Mapping

Domestic vs export ratio. Customer concentration. Inter-company billing if applicable. We map this in 60 minutes — and the structuring recommendation falls out of the map.

02

Monthly GST Refund Filing

RFD-01 every month — we do not let your ITC sit with the government. Refund tracker shared monthly. Deficiency memos addressed within 7 days.

03

Quarterly Compliance Review

GST returns reconciliation, advance tax computation, TP positions, forex revenue recognition — reviewed every quarter so nothing surfaces in March.

04

Annual TP & Tax Planning

Annual TP documentation refresh, tax position planning for next FY, Section 10AA / 80-IAC eligibility check, ESOP year-end tax. Done before the new FY starts.

Why IT/SaaS Founders Choose Pujara & Co

What you actually get — that a generalist CA cannot give.

40+ active IT/SaaS retainers

Software is not a sideline practice for us. We see the same MSA structures, same Stripe payment flows, same Wise transfers, same RazorpayX setups every week. Your stack is our stack.

₹50 Cr+ in GST refunds processed

Not a one-time recovery. Monthly refund filings as standard practice. We track every RFD-01 to closure. If your refund is older than 90 days — that is an exception, not a system.

TP across US, UK, Singapore, Netherlands

Direct experience with TP studies for clients with related parties in each. Different benchmarking pools, different functions/risks, different DTAA treatments. We are not Googling Section 92.

4 SEZ unit setups in 24 months

SEZ is not an old-world tax concept — it remains the single biggest tax break for export-focused companies post 115BAA. We have set up units in Gujarat SEZ properties and supported clients through Section 10AA computations year-over-year.

Same team — every quarter

Your finance person speaks to the same junior CA every month. Your founder speaks to the same senior CA every quarter. No "let me check with my colleague" — the person handling your file knows your file.

Pre-revenue to ₹50 Cr ARR — the same firm

We retain founders from incorporation through Series B. Tax positions in Year 1 affect tax positions in Year 6. Continuity over time = compounding tax efficiency.

A Real Client Situation

₹2.8 Cr stuck in unclaimed GST refunds. Recovered ₹2.4 Cr in 7 months.

Case · GST Refund Recovery

40-person SaaS company, US-only revenue, refunds backlogged 18 months.

The company came to us with a single number stuck in their head: ₹2.8 Cr of unclaimed GST input tax credit. Their previous CA had filed RFD-01 applications quarterly but never followed up on deficiency memos. Some applications had aged past the time-bar. Others sat with vague "documents required" responses unaddressed.

We took over. Reconstructed 18 months of refund applications. Addressed each deficiency memo with proper supporting documentation — invoice copies, FIRC, BRC, GSTR-2A reconciliation. Engaged with the Range Officer for the time-barred applications under condonation grounds. Recovered ₹2.4 Cr within 7 months of takeover. The remaining ₹40 L was time-barred beyond recovery.

Since then, we file RFD-01 monthly. Deficiency memos are addressed within 7 working days. Their refund cycle is now 60-90 days end-to-end.

₹2.4 Cr recovered in 7 monthsMonthly refunds since60-90 day cycle now standard
Anonymised. Specific numbers and timelines representative of typical outcomes.
Frequently Asked Questions

SaaS / IT founder questions, answered straight.

SEZ vs DTA — which makes more sense for my SaaS company?

Three factors: (1) Revenue mix — SEZ benefit only on export turnover; if > 80% export, SEZ wins. (2) Profitability — Section 10AA gives 100% deduction on profits; if you are loss-making, deduction has no current value (carried forward, but devalued). (3) Team size + premises commitment — SEZ requires operating from SEZ space. For a profitable, 25+ person company with mostly US revenue, SEZ saves 22% on profits for 5 years and 11% for next 5 — material. Below those thresholds, DTA is simpler.

What is Section 10AA and how much tax does it actually save?

Section 10AA grants 100% deduction of profits derived from export by an SEZ unit for the first 5 consecutive AYs, and 50% deduction for the next 5 AYs. Practical effect: for a profitable SaaS company with ₹10 Cr profit fully from export, that's ₹2.2 Cr saved per year for 5 years, then ₹1.1 Cr for 5 years = ~₹16.5 Cr over 10 years. MAT under Section 115JB still applies (15% on book profit) — but the gap is large and worth it.

Are STPI tax benefits still available?

STPI tax holiday under Section 10A / 10B has expired (sunset clauses ended in AY 2011-12 for 10A, AY 2010-11 for 10B). New STPI units do not get income tax benefit. STPI registration is now mostly used for operational simplicity — softex filings, customs procedures, bonded premises. Tax-wise, STPI = same as DTA = 22% under 115BAA.

How does GST work for software exports?

Export of services is "zero rated" under IGST. Two routes: (1) With LUT (Letter of Undertaking) — no IGST charged on invoice, ITC on inputs accumulates and is refunded via RFD-01. This is the standard route for most exporters. (2) With IGST payment — pay IGST upfront and claim refund. Operationally heavier, less common. Either way, the export must satisfy the test: place of supply outside India, payment in convertible foreign exchange, supplier and recipient not merely establishments of the same person.

What is an LUT and do I need one?

LUT — Letter of Undertaking — is filed annually (Form GST RFD-11) declaring that export will be made without payment of IGST. Validity: one financial year. Without LUT, you must charge IGST on export and claim refund. With LUT, export goes zero-rated with simpler GST refund mechanics. Every export-focused company should file LUT each April. Conditions: not prosecuted under GST/Customs/IT for tax evasion above ₹2.5 Cr.

How long do GST refunds take?

Statute prescribes 60 days from RFD-01 filing if accepted as is. Reality: deficiency memos extend this. With clean documentation and prompt deficiency response, end-to-end is typically 60-90 days. Without active follow-up, refunds sit indefinitely. We file monthly because (a) cash flow matters and (b) older refunds are harder to push.

Why are my GST refund applications getting deficiency memos?

Most common reasons: GSTR-2A vs GSTR-3B mismatch, missing FIRC / BRC for export proof, ITC claimed on supplies from non-compliant vendors, place-of-supply documentation insufficient, or LUT validity expired during the refund period. Each of these has a documented response. We address them before re-submission, not at re-submission.

What is transfer pricing and when does it apply?

Transfer pricing rules require that transactions between related parties (e.g., Indian SaaS company billing its US parent for engineering services, or Indian subsidiary buying IP licence from foreign holdco) be priced at "arm's length" — what unrelated parties would charge. Applies to all international transactions between Associated Enterprises, regardless of monetary threshold. Documentation is mandatory above ₹1 Cr threshold of international transactions. Form 3CEB filing is annual.

I bill my US parent company for services. What TP documentation do I need?

You need a TP study annually establishing arm's length pricing — typically using TNMM (Transactional Net Margin Method) for services. Includes: company-level functional/asset/risk analysis, comparable company benchmarking, margin computation, justification of pricing. Filed annually as Form 3CEB. If transactions exceed ₹50 Cr, additional master file (Form 3CEAA) and possibly CbC report (Form 3CEAD). Without documentation, the AO can make adjustments at his discretion — typically upward, with interest and penalty.

How is forex revenue recognised — at invoice date or collection date?

For income tax: revenue is recognised at the rate prevailing on the date of revenue accrual (typically invoice date / contract milestone, depending on accounting policy). Subsequent forex gains or losses on the receivable until collection are accounted as forex gain/loss separately. For Ind AS 21 entities: monetary items (receivables) are translated at closing rate at year-end — exchange differences hit P&L. Most software exporters under ICDS recognise revenue at invoice date.

Can I claim foreign tax credit for tax withheld by my US client?

Yes, if the Indian company is a tax resident and the foreign tax was paid on income that is also taxable in India. File Form 67 (online, before ITR filing). Claim is limited to the lower of: foreign tax paid, or Indian tax on that income. India-US DTAA Article 25 governs the credit — services typically attract 0% withholding under DTAA when proper TRC + Form 10F is given to the US client; but if WHT is deducted, FTC under Section 90 recovers it.

Do I need a Tax Audit if I'm a software exporter?

Tax Audit (Section 44AB) applies if your revenue exceeds ₹1 Cr, or ₹10 Cr if cash receipts/payments are below 5%. Most software companies are well under the cash-component limit, so the ₹10 Cr threshold applies. Statutory Audit under Companies Act applies to every Pvt Ltd regardless. Both filings overlap in scope but are separately mandated.

What is Ind AS 21 and does it apply to my company?

Ind AS 21 — Effects of Changes in Foreign Exchange Rates — applies to entities preparing financials under Ind AS (large unlisted companies above prescribed thresholds, listed entities, IPO-bound entities). It governs: translation of foreign currency transactions, period-end translation of monetary items, and translation of foreign operations. Most early-stage software companies are not Ind AS-applicable and use ICDS / Indian GAAP — simpler treatment, but still subject to ICDS VI rules on forex.

We import software/SaaS subscriptions from abroad — what's the GST treatment?

Reverse charge mechanism (RCM) under Section 9(3) of CGST applies. The Indian recipient pays GST at 18% on the import of services, then claims ITC. Practically: every AWS, GitHub Enterprise, Slack, Notion bill from abroad triggers RCM GST. Many companies miss this. If the foreign supplier is registered under OIDAR for B2C, they collect GST themselves; for B2B, the Indian recipient handles it. We track this monthly in your books.

Ready to Talk?

Book a free 60-minute structuring call.

Bring your revenue mix, team size, customer locations, and growth plan. We will model SEZ vs DTA vs foreign sub — and the tax cost of each over 10 years. Concrete numbers. Yours.

Direct (CA Mitul Pujara)
Visit
A-309, Privilon, Iskcon Cross Road, Ahmedabad