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Madhav Pratinidhi

Associate in the Tax Practice at the Mumbai office of Cyril Amarchand Mangaldas. Madhav advises on various aspects of direct tax, with a focus on corporate taxation and international taxation. His experience also extends to indirect tax matters, including customs and goods & services tax. He can be reached at madhav.pratinidhi@cyrilshroff.com

Treaty Shopping Safari Ends Here: Footprints from Tiger Global

Summary:

The Supreme Court’s ruling in Tiger Global International Holdings has redrawn the contours of India’s tax landscape. By rejecting treaty shopping structures and affirming the reach of GAAR even for legacy investments, the Court has signalled a decisive shift toward substance-over-form in cross-border taxation. TRCs are no longer conclusive shields, and investors must now demonstrate genuine commercial substance to claim treaty benefits. This landmark judgment underscores India’s firm stance against tax avoidance and sets the tone for heightened scrutiny of offshore investment structures going forward.Continue Reading Treaty Shopping Safari Ends Here: Footprints from Tiger Global