GAAR As Supreme Sovereign: A Critical Doctrinal Analysis Of The Supreme Court's Judgment In Authority For Advance Rulings V. Tiger Global International Holdings And The Unravelling Of India's Treaty A
IJLLR Journal
Dr. Priyanka Anand, National Law University Odisha ABSTRACT The Indian Supreme Court's ruling in Authority for Advance Rulings (Income Tax) v. Tiger Global International II Holdings has ushered in a sea change in the judicial interpretation of double taxation avoidance treaties, the General Anti- Avoidance Rule (GAAR), and the sanctity of grandfathering provisions protecting pre-April 2017 foreign investments in India. The January 2026 judgment stems from the infamously high-profile Tiger...