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Analysis
Tiger Global: SC says ‘tax sovereignty comes first’ but verdict raises questions
The ruling in favour of Revenue leaves open several issues around indirect transfers, GAAR protections, and Tax Residency Certificates
19th Feb 2026
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Analysis
Trick or treaty
Last month’s ruling in the Tiger Global case has triggered a scramble to revisit legacy structures in cross-border transactions
9th Feb 2026
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The Authority for Advance Rulings (Income Tax) v Tiger Global International II Holdings
The Supreme Court held that the AAR may reject an application at the threshold under Section 245R(2)(iii) where a transaction is prima facie designed for tax avoidance and that a TRC does not bar scrutiny of treaty abuse or control
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Bench:J.B. Pardiwala J, R. Mahadevan J