by Azmul Haque and Shaktibhushan Shukla As tax authorities globally intensify their focus on economic substance, treaty-based investment structures are facing heightened scrutiny. Against this backdrop, this article analyses the Indian Supreme Court’s decision in Tiger Global–Flipkart (15 January 2026) and its implications for treaty entitlement, including the evidentiary limits of tax residency certificates, the narrowing scope of grandfathering protection, and the expandin