The Tiger Global ruling has predictably triggered debate around indirect transfer provisions. My take, as quoted in MoneyControl, on the ramifications of the ruling on indirect transfers post this ruling:
“The Supreme Court’s Tiger Global ruling materially recalibrates India’s indirect transfer landscape. Offshore exits involving Indian assets will now be judged on where real control, governance and economic risk sit, not merely on treaty residency. For investors, this shifts deal planning from jurisdictional optimisation to substance engineering, with holding structures, decision-making protocols and exit mechanics needing to withstand scrutiny well before the transaction stage.”