The AAR's recent judgment on Tiger Global will give ammunition to tax officers to go beyond the legal form of an entity claiming tax exemption under bilateral treaties and assess its management and control, experts said.
The Authority for Advance Rulings (AAR) in a recent order rejected Tiger Global's application for exemption from payment of capital gains tax on sale of its stake in Flipkart to Walmart in 2018.
US-based PE firm Tiger Global had invested in Flipkart through its Mauritius arm.
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