THE AUTHORITY FOR ADVANCE RULINGS (INCOME TAX) vs. TIGER GLOBAL INTERNATIONAL II HOLDINGS
C.A. No.-000262-000262 - 2026Supreme Court15 Jan 2026
Bench: HON'BLE MR. JUSTICE R. MAHADEVAN
928
24th April, 2012
5.5.
Thereafter, Singapore Co. invested in multiple companies in India, and
the value of its shares was derived substantially from assets located in India.
The assessees transferred shares of Singapore Co. ("Sale Shares") held by them
to Fit Holdings S.A.R.L ("Buyer"), a company incorporated under the laws of
Luxembourg. These transfers were undertaken as part