https://www.taxtmi.com/forum/issue?id=120730 Strict application of GAAR and a narrow DTAA reading in the Flipkart-Walmart judgment prioritises substance over form, increases scrutiny of treaty benefits and tax driven structures, and may raise risk and cost of capital for foreign investment in high growth, loss making startups; policymakers should offer prospective clarity, substance based incentives, and treaty modernisation, while startups should bolster commercial substance and documentation. en-us Fri, 23 Jan 2026 09:32:31 +0530 Fri, 23 Jan 2026 18:08:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=120730 Strict application of GAAR and a narrow DTAA reading in the Flipkart-Walmart judgment prioritises substance over form, increases scrutiny of treaty benefits and tax driven structures, and may raise risk and cost of capital for foreign investment in high growth, loss making startups; policymakers should offer prospective clarity, substance based incentives, and treaty modernisation, while startups should bolster commercial substance and documentation. Discussion-Forum Income Tax Fri, 23 Jan 2026 09:32:31 +0530 https://www.taxtmi.com/forum/issue?id=120730