The Evolution of TRC from Azadi to Tiger Holding

J the app position for today sorrounds the validity of TRC post Tiger Global case. The debate has become a structural contest between treaty form and administrative substance. Across successive decisions, culminating in Tiger Global Holdings, the Supreme Court has clarified that treaty residence is a juridical status arising from Sovereign agreement and evidenced through certification. This note traces that doctrinal arc and examines how the Court has ultimately drawn a firm boundary around the permissible role of substance in denying treaty residence.