Income Tax

Background of the case In a landmark judgment, the Supreme Court of India, in the case of Tiger Global International II Holdings & Ors. (2026 INSC 60), has settled several long-standing controversies relating to taxation of indirect transfers, treaty shopping, the evidentiary value of Tax Residency Certificates (“TRCs”), and the scope and application of General […]

In an interesting development in the case of Hinduja Global Solutions Limited (“HGSL”), the Bombay High Court, by its interim order dated 19 December 2025, admitted the writ petition filed by HGSL and granted interim relief. Background The GAAR panel had passed a directive characterizing the treatment of tax losses under the demerger of NXT […]

Background of the case In August 2021, Hinduja Global Solutions Ltd (“HGSL” or “the Company”) announced that it has entered into definitive agreements to divest its Healthcare Services business (“HS business”) to funds affiliated with Baring Private Equity Asia (BPEA), one of the largest private alternative investment firms in Asia. On January 6, 2022, the […]

Background In a recent ruling, the Telangana High Court (“the Court”) in the case of Spectra Shares and Scrips Limited (“the assessee” or “the Company”) decided on the tax treatment of the transfer of an entire bottling and marketing undertaking carried out for AY 1998-99. The Company was engaged in bottling and marketing Coca-Cola beverages […]

Background In a recent ruling, the Delhi High Court (“the Court”), in the case of PMV Maltings (P) Ltd (“the Company” or “the Assessee”), examined the interpretation of Fifth Proviso to Section 32(1) of the Income-tax Act, 1961 (“the Act”), in the context of depreciation claims following a demerger. The assessee acquired two malt production […]