The Substance Arc: Azadi Bachao to Tiger Global
From the 2003 ruling that a Mauritius certificate sufficed to the 2026 ruling that substance governs: the shift every investor into India must understand.
Read articleFrom the 2003 ruling that a Mauritius certificate sufficed to the 2026 ruling that substance governs: the shift every investor into India must understand.
Read articleVodafone and Sanofi faced the same indirect-transfer charge and reached opposite results. The difference was the treaty. Why holding-jurisdiction choice decides.
Read articleVodafone and Cairn show the one risk no structure carries — a change in law applied after the deal — and the two tools that answer it: the treaty and the contract.
Read articleCompanies used India’s MFN treaty clause to claim lower withholding rates. The Supreme Court held the benefit needs a notification. The reliance lesson.
Read articleWhat India’s landmark cross-border cases teach about durable structuring — and how the framework has matured. Read for the lesson, not the verdict.
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