Core Viewpoint - The Supreme Court of India emphasized the need for tax treaties to prioritize national interest and safeguard the country's economic sovereignty while ensuring fairness and preventing abuse in international tax agreements [5][6][7]. Group 1: Tax Treaty Principles - Justice Pardiwala highlighted that tax treaties should be engaging, transparent, and subject to periodic reviews, with the ability to renegotiate and include strong exit clauses to prevent unfair outcomes [2][6]. - The treaties must incorporate limitations of benefits clauses to prevent treaty shopping by shell companies and allow for domestic anti-avoidance laws like the General Anti-Avoidance Rule [6][7]. - The overarching goal of treaties should reflect broader economic and public interests rather than merely bureaucratic or diplomatic objectives [6][7]. Group 2: Case Context - The Supreme Court's observations were made in the context of a judgment regarding the taxation of capital gains from Tiger Global's exit from Flipkart in 2018, which was deemed taxable in India [7]. - Tiger Global had sought an Advance Authority Ruling from the Income Tax Department in February 2019 concerning this matter [7].