Policy

Treaty shopping disputes in India are moving from form to substance. After Tiger Global, the real issue is no longer paperwork alone, but who actually controls income, risk, and exit.

India's tax-certainty architecture now rests on three very different routes. BAR offers domestic legal clarity, MAP delivers treaty relief, and APA has become the most institutionalised option for recurring transfer-pricing risk. The right choice depends on timelines, bilateral exposure and how much confidentiality a boardroom really needs.

Capital vs revenue lines are fraying in India’s digital economy. SaaS subscriptions, cloud infrastructure, and data-driven intangibles create enduring benefits without durable assets, forcing doctrine to chase new facts

A tax opinion in 2026 survives less on elegant citation than on facts, disclosure and process. As scrutiny gets more data-rich, defensibility now begins long before the notice arrives.

AI-generated invoices may be legally recognisable in India, but scrutiny turns on something harder than neat drafting: provenance, system control, metadata, and whether the transaction trail still holds under challenge.