Indian Supreme Court Rules Against Tiger Global in Landmark Tax Decision Over Walmart Transaction

On January 16, 2026, India's Supreme Court ruled that Tiger Global's $1.6 billion stake sale in Flipkart to Walmart is subject to taxation under national law.

Insights:
The Indian Supreme Court delivered a landmark ruling on Thursday, January 16, 2026, determining that Tiger Global must pay taxes in India ININfor its 2018 sale of a $1.6 billion stake in Flipkart to Walmart Inc. . The 152-page decision establishes that the country's General Anti-Avoidance Rule, known as GAAR, can override bilateral treaty benefits when a transaction is found to lack genuine commercial substance. This ruling marks a significant shift in how the Indian tax administration handles foreign investment structures previously routed through Mauritius MUMU.
FILE PHOTO: A woman checks her mobile phone inside the premises of the Supreme Court in New Delhi, India, September 28, 2018. REUTERS/Anushree Fadnavis/File Photo
FILE PHOTO: A woman checks her mobile phone inside the premises of the Supreme Court in New Delhi, India, September 28, 2018. REUTERS/Anushree Fadnavis/File Photo
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