Ultimately, Tiger Global will bring radical accountability to international investment law. The biggest question is whether unilateral source-country anti-abuse measures can be adopted within the existing treaty framework or whether renewed multilateral coordination is necessary.

This case will probably initiate closer examination in similar disputes, such as the case of Blackstone Capital Partners v. ACIT (Blackstone) before the Delhi High Court, and Sanofi Pasteur Holding v. Department of Revenue (Sanofi) case before Andhra Pradesh High Court.

The line between inquiry and proceedings should therefore be drawn not at the formal commencement of adjudication through a SCN, but at the point where the State deploys coercive power against the taxpayer.

The Supreme Court did not see the issue in Tiger Global as an isolated dispute over taxation. It viewed the issue against the broader backdrop of treaty interpretation and the play of sovereign powers.

The Delhi High Court’s decision in Equity Intelligence AIF effectively addresses a decade-long tax conundrum for Category III AIFs by applying the doctrine of impossibility.

Even if a limited risk exercise is permissible as a matter of policy, a blanket conditionality on 90% provisional refunds is disproportionate.

A durable resolution can be achieved only through a targeted legislative intervention, either by expressly incorporating the “date of transfer” principle into the new clause or by prescribing definitive timelines for such transfer.

[ Vaibhav is a student at West Bengal National University of Juridical Sciences . ] The advent of arbitration has not only introduced a host of complexities within arbitration law but has also extended its influence into the sphere of taxation law. The author brings to light an emerging issue in the taxability of the post-award interest component of these awards through this piece. The issue revolves around the fundamental question: under which head of income in the double ta

The 2025 update of the OECD commentary represents an important step towards harmonizing the definition of PE in modern business practices in cross-border remote work and mobile extractive industries.

India’s aviation sector is at a defining moment as airlines like IndiGo aim of flying beyond domestic skies and venture into international markets. However, the current structure of ATF taxation imposes a disproportionate burden on airlines and restricts their ability to compete.

Better clarity is required from the government and the courts regarding the anti-profiteering system.

The split in ACIT v. Shelf Drilling Ron exposes a deeper fault line in Indian tax adjudication: whether courts should privilege the literal boundaries of statutory text or stretch interpretation to preserve the functional life of specialized procedures.

The retrospective amendment made by the Union is a massive blow to the Safari Retreats judgement, as it has essentially nullified it.

The broad legal reasoning adopted by the court may be invoked in future disputes, raising concerns regarding a roadmap for future regulation and taxation. Applying the aspect theory here may result in jurisdictional overreach and risk upsetting the delicate federal balance enshrined in the Constitution of India.

India now stands at the crossroad of remaking transfer pricing not merely a regulatory stick, but a strategic tipping stone of fair trade, investment confidence and tax equity.

The article argues for the continuance of the current judicial framework which calls for looking at each case from a businessman’s point of view to check the owner’s intention behind leasing the asset.

The post aims to analyze this dissonance in the regulatory approach taken by the USA and India in taxing carried interest.

As per the author, the recent tax evasion allegations against Kia and Volkswagen highlight gaps in the current CKD classification system.

The taxation framework presents significant challenges that hinder the growth and adoption of VDAs in India.

The suspension of the MFN clause in the India-Switzerland DTAA is a significant shift in international tax treaties.

The proposed amendment to Sections 72A and 72AA of ITA reflects government’s intent to curb tax avoidance through evergreening of losses.

With attractive tax exemptions on EVs, the government has made remarkable strides in promoting EVs.

The ruling may act as a catalyst for tax reforms, aligning the tax regime with the dynamic realities of corporate restructuring.

While the judgment provides a temporary solution to a specific problem, it may have created a template for judicial intervention.