‘Transaction stood grandfathered by virtue of Article 13(3A) of India-Mauritius DTAA’; Delhi HC quashes AAR order holding Tiger Global-Flipkart transaction as ‘aimed at tax avoidance’
Merely because a parent entity may exercise shareholder influence over its subsidiary that would not lead to an assumption that the subsidiary in question was operating as a mere puppet or that it was wholly subservient to the parent entity.