top of page
From Treaty Shield to Tax Scrutiny: Decoding the Tiger Global Case
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.
Abhishek Pandey, Shriyansh Sameer Mishra
Apr 1910 min read
The Impact of Tiger Global on Treaty Protection and Exit Strategies in India
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.
Amritanshu Rath, Shreya Tiwari
Apr 77 min read
Tax Implications of Cross-Border Arbitral Awards: Addressing Inconsistencies in Indian Jurisprudence
[ 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
Vaibhav Tibrewal
Mar 710 min read
Impact of Switzerland’s Suspension of MFN Clause in India-Switzerland DTAA: A Shift in Global Tax Dynamics
The suspension of the MFN clause in the India-Switzerland DTAA is a significant shift in international tax treaties.
Suhana Roy
Mar 20, 20258 min read
Unveiling Non-Taxability of Compensation Payment to Cricket South Africa under the India-SA DTAA
This piece delves into the intricate facets of BCCI v. Dy. Commissioner of Income Tax.
Vaishnavi Chandrakar
Jun 15, 20237 min read
Beyond the Transaction: (Mis)application of the Principle Purpose Test
Author analyzes the confrontational approach of tax authorities towards foreign investment in India, focusing on the principle purpose test.
Sharun Salvi
Mar 6, 20236 min read
bottom of page