23 Sep 2025


This is a link-enhanced version of an article that first appeared in MoneyControl
Article Overview:
This article highlights the impact created by the Delhi Income Tax Appellant Tribunal (ITAT) verdict by bringing tax-relief for Foreign Potential Investors (FPIs) who have invested into India through Mauritius/Singapore route.
Our Partner, Himanshu Sinha, Tax, Trilegal shared his perspective. Here’s what he had to say:
“This verdict adds to the jurisprudence of tax certainty laid down by tax tribunals from across the country over the last decade – for non-resident funds/companies/family offices investing in Indian securities other than shares. While the treaty doesn’t define the term ‘shares’ – even under domestic Indian laws, ‘shares’ and ‘units of a mutual fund’ are classes of assets with entirely different rights and obligations, and regulated under different companies and securities laws.”
Download PDF
Deal: Trilegal is advising GIC on the acquisition of 100% shareholding of Aseem Infrastructure Finance by TPG-led consortium

Selling property in India? Here’s how NRI’s can avoid excess TDS

Deal: Trilegal advises on Adani Enterprises’ landmark INR 150 billion QIP, one of India’s largest equity fundraises
Under the rules of the Bar Council of India, Trilegal is prohibited from soliciting work or advertising in any form or manner. By accessing this website, www.trilegal.com, you acknowledge that:
We prioritize your privacy. Before proceeding, we encourage you to read our privacy policy, which outlines the below, and terms of use to understand how we handle your data:
For more information, please read our terms of use and our privacy policy.