Hemanya Pratap Singh & Tathagat Singh, LL.B. (Hons.), Jindal Global Law School, Sonipat ABSTRACT The Principal Purpose Test, incorporated in India’s Double Taxation Avoidance Agreements by virtue of the Multilateral Instrument (‘MLI’) since October 2019, has spawned a doctrinal development that legal literature is yet to acknowledge: far from a simple restructuring of India’s treaty anti-avoidance rules, it makes the legitimacy of the structuring of corporate entities across borders a...