[Letterhead of Greenberg Traurig, P.A.]
                                                                     Exhibit 8.2

                                        January 18, 2001

Silverline Technologies Limited
Unit 121, SDF IV
SEEPZ, Andheri (East)
Mumbai (Bombay) 400096
India

     Re:  Federal Income Tax Considerations Relating to Silverline Technologies
          Limited Form F-4 Registration Statement

Ladies and Gentlemen:

     We have acted as counsel to Silverline Technologies Limited, a corporation
organized under the laws of India (the "Company"), in connection with the
issuance of its American depositary shares ("ADSs") in connection with the
proposed merger of SeraNova, Inc. ("SeraNova") with a subsidiary of the Company
and the preparation and filing of Amendment No. 1 to a registration statement on
Form F-4 to be filed by the Company with the Securities and Exchange Commission
on January 18, 2001 (the "Registration Statement") and the prospectus contained
therein (the "Prospectus").

     In rendering our opinion, we have reviewed the Registration Statement and
the Prospectus and the documents attached as exhibits thereto, and we have
assumed that the statements therein are and will remain true, correct and
complete and that actions described in the Prospectus have been or will be taken
as described. In addition, we have received and relied on certifications of fact
from both the Company (and Silverline Acquisition Corp.) and SeraNova. We have
assumed the conformity to the originals of all documents submitted to us as
copies and the authenticity of the originals of all of those documents. We have
assumed that all factual matters in documents submitted to us and all of the
other information furnished to us are true, correct and complete. We have
assumed that any representation or statement made "to the knowledge of," "to the
best knowledge of" or otherwise similarly qualified is correct without such
qualification. As to all matters in which a person or entity making a
representation has represented that that person or entity either is not a party
to, does not have, or is not aware of, any plan, intention, understanding or
agreement, there is in fact no such plan, intention, understanding or agreement.

     Based on the foregoing, in reliance thereon and subject thereto, and based
on the Internal Revenue Code of 1986, as amended, the Treasury regulations
promulgated thereunder, administrative pronouncements of the Internal Revenue
Service and judicial decisions, all as in


Silverline Technologies Limited
January 18, 2001
Page 2

effect on the date hereof, it is our opinion that the statements set forth in
the Prospectus under the caption "MATERIAL U.S. FEDERAL INCOME TAX
CONSEQUENCES", insofar as they purport to describe the matters of law referred
to therein, represent the material U.S. federal income tax considerations
relevant to United States persons who will acquire ADSs of the Company pursuant
to the proposed merger.

     The foregoing opinion is limited to the matters expressly set forth, and no
opinion is to be implied or inferred beyond the matters expressly stated. This
opinion speaks only as of the date hereof and is based solely on legal
authorities as they currently exist. Those legal authorities are subject to
change either prospectively or retroactively, and we assume no obligation to
update or supplement this opinion. In addition, any variation or difference in
the facts from those set forth or assumed herein may affect the conclusion
stated herein.

     This opinion is furnished to you for use in connection with the
Registration Statement and the Prospectus. We hereby consent to the filing of
this opinion letter as an exhibit to the Registration Statement.

                                        Very truly yours,

                                        /s/ Greenberg Traurig, P.A.

                                        Greenberg Traurig, P.A.