Safari Retreats did not abolish blocked credit under GST. It changed the argument. This article reads the judgment as a principles case, tracks the legislative response, and explains where the construction ITC fight now really sits.
Even without Indian implementation, Pillar Two can still hit Indian groups through foreign IIR and UTPR rules, reshaping cash-tax outcomes, reporting systems and capital allocation decisions.
Mutual Agreement Procedure is increasingly central to India's tax-certainty architecture. The real strategic mistake in 2026 may not be using MAP - it may be using it too late.
India’s APA regime has crossed the proof-of-concept stage. For large taxpayers in 2026, the real question is no longer whether a case can be fought, but whether recurring litigation still delivers more value than certainty.
