[Krupali is a student at Gujarat National Law University.] On 15 January 2026, the Apex Court in Tiger Global International II Holdings v. AAR (Tiger Global) denied treaty relief under the India-Mauritius DTAA, relying on the doctrine of substance over form. Eleven months before then, in SC Lowy PI (LUX) SARL v. ACIT (SC Lowy), the Income Tax Appellate Tribunal, Delhi delivered India’s first judicial application of the principal purpose test (PPT). This was followed by the In