Tiger Global International III Holdings v. AAR

468 ITR 405High Court2024#18462 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2025 to 2025.

Sections most often in play

Section 143(3)Section 144C(13)Section 234BSection 9(1)(vi)Section 5(1)Section 11Section 12Section 7

Issues it is cited on

principal purpose testmultilateral instrumentsection 90(1)treaty benefitsfixed place peppttax residency certificateazadi bachao andolantrcmlisection 9(1)(vi)directions of the drp

Judgments citing Tiger Global International III Holdings v. AAR

SKY HIGH II LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1550/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…nue to show that PPT is not satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures are not applicable to the present case. (iii) Ratios of precedents like UOI v. Azadi Bachao Andolan [2003] 263 ITR 706 (SC), Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) and Vodafone International Holdings BV v. UOI [2012] 341 ITR 1 (SC) were no lo…

SKY HIGH LXXX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1549/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…nue to show that PPT is not satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures are not applicable to the present case. (iii) Ratios of precedents like UOI v. Azadi Bachao Andolan [2003] 263 ITR 706 (SC), Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) and Vodafone International Holdings BV v. UOI [2012] 341 ITR 1 (SC) were no lo…

SKY HIGH LXXVIII LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1548/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…nue to show that PPT is not satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures are not applicable to the present case. (iii) Ratios of precedents like UOI v. Azadi Bachao Andolan [2003] 263 ITR 706 (SC), Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) and Vodafone International Holdings BV v. UOI [2012] 341 ITR 1 (SC) were no lo…

SKY HIGH XC LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1547/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23
Section 143(3)Section 234B

…to show that PPT is not satisfied is based only on\nreasonableness and not strictly evidence based.\n(ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause),\nhence the precedents like Tiger Global International III Holdings v. AAR\n[2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV\nbased structures are not applicable to the present case.\n(iii) Ratios of precedents like UOI v. Azadi Bachao Andolan [2003] 263 ITR\n706 (SC), Tiger Global International III Holdings v. AAR [2024] 468 ITR\n405 (Delhi) and Vodafone International Holdings BV v. UOI [2012] 341\nITR 1 (SC) were…

SKY HIGH LXXIX LEASING COMPANY LIMITED ,MUMBAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) CIRCLE 4(2)(1), MUMBAI

ITA 1546/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Oct 2025AY 2022-23

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 143(3)Section 9(1)(vi)

…nue to show that PPT is not satisfied is based only on reasonableness and not strictly evidence based. (ii) India-Ireland DTAA does not give a LOB (Limitation of Benefits clause), hence the precedents like Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) that have examined treaty eligibility for SPV based structures are not applicable to the present case. (iii) Ratios of precedents like UOI v. Azadi Bachao Andolan [2003] 263 ITR 706 (SC), Tiger Global International III Holdings v. AAR [2024] 468 ITR 405 (Delhi) and Vodafone International Holdings BV v. UOI [2012] 341 ITR 1 (SC) were no lo…