Supreme Court Ruling Strengthens Government’s Position in Tax CasesIndia’s Supreme Court ruling on 15 January has added significant uncertainty for foreign investors, particularly private equity firms, following a judgment that strengthens the government’s hand in tax disputes. The judgment overturned a 2024 Delhi high court decision that had allowed Tiger Global to claim tax relief under the India–Mauritius tax treaty. The investment was made through three Mauritius-based entities, with Tiger Global seeking tax relief based on a long-standing tax treaty between India and Mauritius. Supreme Court’s Ruling on Offshore Investment StructuresIn siding with Indian authorities, the Supreme Court ruled that tax certificates alone are insufficient proof for claiming treaty benefits. Broader Implications for Foreign Investment in IndiaThe ruling has wider implications, particularly as India and Mauritius amended their tax treaty in 2024 to restrict tax benefits only to companies with legitimate businesses.