The Supreme Court of India has ruled that tax treaties must protect the country's tax sovereignty and should be driven by national interest, not foreign or corporate pressure. This came during a case involving Tiger Global, a U.S. investor firm that exited Flipkart in 2018. The court upheld the Indian tax authority's decision that capital gains from this exit are taxable in India. Justice J.B. Pardiwala wrote a separate opinion emphasizing that tax treaties and international agreements should be transparent, regularly reviewed, and include strong exit clauses to prevent unfair outcomes. He said treaties should safeguard India's strategic and security interests, prevent erosion of the tax base, and maintain democratic control. Justice Pardiwala also recommended including limitation of benefits clauses to stop treaty abuse by shell companies and ensuring domestic anti-avoidance laws remain effective. "Treaties should be driven by national interest, not pressure from foreign governments or corporations," he said. Tiger Global had approached the Income Tax Department in 2019 for an Advance Authority Ruling on this issue after Walmart bought a controlling stake in Flipkart. The Supreme Court's detailed guidelines aim to ensure India’s economic sovereignty and public interest are protected in future international tax treaties.