Following the Supreme Court's Tiger Global judgment and CBDT Notifications No. 54 and 55 of 2026, taxpayers expected greater certainty on treaty entitlement for grandfathered investments. Yet recent assessments involving Mauritian taxpayers point to a changing enforcement landscape, with tax authorities increasingly relying on JAAR principles and substance-based challenges to treaty claims.
For investment funds, multinational groups and holding structures, the implications could be significant.
Explore latest developments, understand the evolving assessment approach, and prepare for the next wave of India-Mauritius treaty-related tax disputes.
