In a landmark verdict, the Supreme Court has ruled that Tiger Global’s $1.6-billion stake sale in Flipkart to Walmart is taxable in India, declaring the transaction an “impermissible tax avoidance arrangement.”

The dispute relates to Tiger Global’s 2018 exit from Flipkart as part of Walmart’s $16-billion acquisition. The investment was routed through Mauritius-based entities, with Tiger Global claiming exemption under the India–Mauritius tax treaty. Indian tax authorities argued these entities were merely conduits used to avoid tax.

Justice R. Mahadevan held that the structure was designed to evade taxation and therefore could not claim treaty benefits, overturning a previous Delhi High Court ruling in Tiger Global’s favour.

Calling it a globally watched judgment, government counsel N. Venkataraman said the ruling will shape how India applies tax principles to future cross-border transactions. The decision sets a significant precedent on treaty abuse and international tax planning.