Case of Authority of Advance Ruling vs Tiger Global International Holdings, SC Judgement Dated 15th January 2026. The apex court held that the exemption under Article 13(4) of the Double Taxation Avoidance Agreement cannot be claimed where the transfer of unlisted equity shares is carried out pursuant to an arrangement impermissible under Indian law. The Court noted that the transfer of unlisted equity shares by Tiger Global was not an isolated commercial transaction but formed part of a composite arrangement culminating in Walmart’s acquisition of Flipkart. The Court observed that the factual findings on record established that the manner in which the transfer was structured and executed rendered the arrangement impermissible under Indian law.