Mauritius treaty; Cholesterol in the GST; LLMs for regulatory orders; Unshackling the elephant by Anand Prasad

Recent events around Tiger Global have brought fresh interest in the Indian government’s treatment of taxation of cross-border flows. Renuka Sane and I wrote a column in the Business Standard on 19 January, The value of the Mauritius treaty. We review the economic gains from residence-based taxation. Foreign investors are now deterred by a combination of source-based taxation and legal risk. As with many other aspects of tax policy [link, link], we need to re-center economic policy around the objective of economic growth, instead of the pursuit of tactical revenue gains, third world solidarity, or arbitrary power.

Vijay Kelkar, Arbind Modi and I have been writing about the problems of the GST. In particular, we worry that blockages in input-tax credit have, in many situations, reduced the Indian GST to a traditional style cascading production tax instead of actually being a VAT. To call it a GST has more than a whiff of isomorphic mimicry. We then undertook the detailed legal analysis to identify the pathways through which the present law generates blockages of input-tax credit. This is the paper Input Tax Credit and refunds under GST in India: Conceptual and legal framework, Arbind Modi, Ajay Shah, XKDR Forum Working Paper 44, December 2025. There is an unveiling article on The Leap Blog.

Every regulatory employee is tantalised by the prospect of going to ChatGPT and getting an order done. While this is a terrifying prospect in terms of the over-arching principle of correctness, there are ways in which LLMs can potentially be used sensibly in regulators.

Natasha Aggarwal, Satyavrat Bondre, Amrutha Desikan, Bhavin Patel & Dipyaman Sanyal of Trustbridge have a new paper Can technology augment order writing capacity at regulators?, and they have an unveiling article on The Leap Blog.

Unshackling the elephant is an important new book, by an insider to the Indian law profession, which uniquely questions the foundations of how the Indian legal system works. Siddharth Raman has a book review on The Leap Blog.