The Authority For Advance Rulings ... vs Tiger Global International Ii Holdings

insc-2026-60 Supreme Court of India 15 January 2026 • CIVIL APPEAL NO. 262 OF 2026; CIVIL APPEAL NO. 263 OF 2026; CIVIL APPEAL NO. 264 OF 2026 • 175 min read

26 cases cited (0 SG, 26 foreign) Cited by 1 case

Practice Areas

BA through the Finance Act, 2013 Constitution of India DTAA ceases to govern the transaction and the matter must necessarily be tested under the Income Tax Act, 1961 Finance Act, 1972 Finance Act, 2012 Financial Services Act, 2001 Financial Services Act, 2007 In the explanatory memorandum to the Finance Act, 2012 Income Tax Act, 1961 Income Tax Assessment Act, 1936 Indian Income Tax Act Mauritius Income Tax Act Mauritius Offshore Business Activities Act, 1992 Prior to the Finance Act, 2012 Securities and Exchange Board of India Act, 1992 main legal question was whether the Indian Income Tax Act, 1961

Judges (2)

J.B. Pardiwala Coram R. Mahadevan Delivered

Parties (2)

Authority For Advance Rulings Appellant Tiger Global International II Holdings Respondent

Case Significance

The Authority For Advance Rulings ... vs Tiger Global International Ii Holdings is a Supreme Court of India decision dated January 15, 2026 (citation: insc-2026-60). Civil appeals concerning advance ruling on tax treaty interpretation involving Tiger Global, a foreign investment entity. The Supreme Court adjudicated the batch of connected appeals on the interpretation of bilateral tax treaties and their domestic implementation. The bench comprised Justices J.B. Pardiwala and R. Mahadevan. The judgment was delivered by Justice R. Mahadevan.

This case has been cited by 1 subsequent judgment. The judgment references 26 case citations.

Summary

Civil appeals concerning advance ruling on tax treaty interpretation involving Tiger Global, a foreign investment entity. The Supreme Court adjudicated the batch of connected appeals on the interpretation of bilateral tax treaties and their domestic implementation.

What was the outcome of The Authority For Advance Rulings ... vs Tiger Global International Ii Holdings?

Cases Cited (26)

IN (26)

(1963) 2 SCR 747 (1968) 3 SCR 41 (1969) 1 SCR 988 (1969) 2 SCC 283 (1973) 3 SCC 585 (1975) 2 SCC 302 (1978) 2 SCC 50 (1985) 3 SCC 230 (1985) 4 SCC 124 (1986) 1 SCC 264 (1994) 6 SCC 77 (1997) 1 SCC 326 (1999) 8 SCC 667 (2003) 5 SCC 298 (2004) 10 SCC 1 (2012) 6 SCC 613 (2016) 6 SCC 602 2001 INSC 519 2026 INSC 60 AIR 1958 SC 79 AIR 1962 SC 1753 AIR 1967 SC 819 AIR 1968 SC 1138 AIR 1969 SC 932 AIR 1981 SC 1922 AIR 2023 SC 5551

Cited By (1)

insc-2026-60

The Authority For Advance Rulings ... vs Tiger Global International Ii Holdings

Judgment

Read the full judgment on the official India Courts portal.

Read on Indian Kanoon

Source: Indian Kanoon (insc-2026-60)