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Intelligence for Better Decision Making
Erudite Risk takes an all risks approach to intelligence reporting. We categorize key intelligence into one of 40 different risk intelligence categories.
The goal is to provide intelligence that allows decision makers to avoid being blindsided by what they may have missed, while informing them to make better decisions as well.
Erudite Risk also includes operations categories so you can monitor the environment for better decision making. Everything is tied together--what happens in risk affects operations and what happens in the market impacts risk profiles.
We categorize key intelligence into one of 30 different operations intelligence categories.
Different roles and functions within the organization can monitor different key issue areas. HR may monitor employment, wages, regulations, labor and management relations, etc., while P&L leaders may monitor overall developing trends.
Supreme Court Rules on Taxability of Capital Gains in India – Denies Mauritius Tax Treaty Benefits and GAAR Grandfathering Protection
AZB & Partners | English | AcademicThink | Jan. 23, 2026 | Regulation
On January 15, 2026, the Supreme Court of India ruled against the Mauritian investment entities of Tiger Global regarding their claim for tax treaty benefits on capital gains from their 2018 sale of Flipkart shares to the Walmart Group. The court emphasized the principle of ‘substance over form’ in the post-GAAR framework introduced in India's Income-tax Act from April 1, 2017.
Tiger Global's Mauritian entities had argued that their gains were tax-exempt under the India-Mauritius DTAA. However, the Supreme Court clarified that DTAA benefits apply only when the transaction is taxable in the non-resident state and rejected the claim for indirect transfer exemptions under Article 13(4) of the DTAA. It was highlighted that the Tax Residency Certificate (TRC) alone does not guarantee treaty benefits, as Indian tax authorities can assess commercial substance beyond the certificate.
The court overturned earlier authorities granting conclusive status to TRCs before GAAR's introduction and established that treaty interpretation must align with domestic anti-abuse laws. GAAR provisions apply even to gains realized after April 1, 2017, regardless of when the original investment was made, and arrangements primarily aimed at tax avoidance without commercial substance can be challenged under GAAR or JAAR.
The Supreme Court found the Tiger Global structure to be prima facie tax-driven, thereby denying DTAA benefits. This judgment underscores heightened scrutiny on treaty benefits and reinforces that substance will prevail over form in tax matters involving cross-border capital gains in India.
India set to release revised Defence Acquisition Procedure 2020 for stakeholder feedback
Hindu Business Line | English | News | Jan. 23, 2026 | Regulation
The Ministry of Defence (MoD) of India is set to release the first draft of the revised Defence Acquisition Procedure (DAP) 2020 within the next 15 days for stakeholder feedback. This revision aims to simplify and shorten the capital acquisition process, targeting a reduction in procurement time to approximately two years by enabling parallel processing of activities. The revised DAP is planned for implementation from April 1, 2026, aligned with the expected increase in the defence budget for FY27.
Key reforms include a gradual scaling of indigenous content requirements for high-technology orders, rather than an upfront high threshold, with potential merging of Buy (Indian) and Buy (Indian-IDDM) categories to simplify procurement processes. The procedure will support ‘Atmanirbhar Bharat’ and ‘Make in India’ initiatives, incorporate emerging technologies such as AI and quantum computing, and strengthen indigenous defence manufacturing.
The revised DAP will also provide greater flexibility for foreign direct investment (FDI) in defence, though the current allowance of 100 percent FDI faces opposition from domestic industry for potentially undermining self-reliance goals. Simplified testing procedures will accept certificates of conformance from accredited labs for non-core parameters, and the revised policy will introduce defence space procurement provisions to tap into India’s growing space economy.
The overarching objective of the DAP review is to position India as a global hub for defence manufacturing and Maintenance, Repair, and Overhaul (MRO), promoting design and development across public and private sectors, with a focus on startups, innovators, and private industry involvement.
TATA group Chairman promises investments in Telangana
Hindu Business Line | English | News | Jan. 23, 2026 | UndeterminedBizdev-Partnering
TATA Group Chairman N Chandrasekaran expressed strong interest in investing in Telangana during a meeting with Chief Minister A Revanth Reddy at the World Economic Forum summit in Davos. The group plans to set up new manufacturing plants in the state and support government initiatives such as the rejuvenation of the Musi river.
The Telangana delegation presented their “Telangana Rising 2047” vision, which includes upgrading major stadiums in Hyderabad, a project TATA has agreed to support. The group also plans to invest in the hospitality sector by establishing hotels in key temple towns like Medaram, Vemulawada, and Bhadrachalam.
Discussions included a world-class resort on the expanding Srisailam highway, leveraging local attractions and infrastructure suitable for business conferences. TATA is ready to partner on this resort initiative. Additionally, the group is optimistic about future investments in AI data centers, semiconductor production, and electric vehicle manufacturing in Telangana.
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