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Supreme Court Upholds Mauritius DTAA Grandfathering on Indirect Transfer of Shares — Tiger Global International Holdings vs Authority for Advance Rulings (2026 INSC 60)
Background of the CaseEvents Leading to the DisputeTiger Global, a global investment
group, divested a significant equity interest (approximately 17%) in Flipkart
in 2018 as part of Walmart Inc.’s acquisition o...
Limitation Under Section 153 Applies to DRP Proceedings Under Section 144C – Assistant Commissioner of Income Tax (International Taxation) v. Shelf Drilling Ron Tappmeyer Ltd., Supreme Court (2025 INSC 946)
The Supreme Court of India, in Civil Appeals arising out of SLP (Civil) Nos. 20569–20572 of 2023, reported as 2025 INSC 946, examined the statutory framework governing assessment proceedings for eligible assessees unde...
Income-tax Prosecution Cannot Continue After Settlement Commission Grants Penalty Immunity Without Proof of Wilful Evasion – Vijay Krishnaswami @ Krishnaswami Vijayakumar v. Deputy Director of Income Tax (Investigation), Supreme Court (2025 INSC 1048)
n the Supreme Court of India, the Criminal Appeals arising out of SLP (Crl.) Nos. 3618–3620 of 2024 were decided on 28 August 2025, reported as 2025 INSC 1048. The appeals were filed by Vijay Krishnaswami challenging t...
Temporary Break in Business Is Not Business Closure – Pride Foramer S.A. vs Commissioner of Income Tax & Anr., Supreme Court (2025 INSC 1247)
In the Supreme Court of India judgment reported as 2025 INSC 1247 delivered on 17 October 2025, the Apex Court addressed appeals arising from Income Tax Appeal Nos. 49 of 2005, 91 & 98 of 2006 relating to assessment ...
Supreme Court Holds Non-Compete Fee as Allowable Revenue Expenditure under the Income-tax Act (Sharp Business System v. CIT-III, 2025 INSC 1481)
FactsThe assessee, Sharp Business System, paid a non-compete fee to another corporate entity pursuant to a commercial arrangement restricting the latter from engaging in competing business activities for a specified peri...