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AAR's Mauritius Treaty Benefits Denial on Flipkart - Walmart Deal: IssuesRequiring Reconsideration

India-Mauritius tax treaty has come under scanner yet again with a recent pronouncement by the Authority for Advance Rulings (“AAR”) in the case of Tiger Global International II Holdings, In re. The AAR was called upon to adjudicate whether capital gains arising from the sale of shares held by Mauritius based Applicant companies [with further holding in a Singapore Company (deriving value substantially from assets located in India)] would be chargeable to capital gains tax in India.



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