TRCs aren’t a free pass anymore?: What SC’s Tiger Global ruling means for foreign investors

A single certificate was once enough to unlock tax treaty benefits in India. Not anymore. The Supreme Court’s January 2026 ruling in the Tiger Global case has redrawn the rules for foreign investors. This story explains what Tax Residency Certificates really are, why the court rulings mean they are not enough on their own, and how this judgment could reshape billions of rupees worth of foreign investments into India.