Direct Tax
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direct_tax
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Delhi High Court affirms the determinate trust characterisation for Category III AIFs
A Division Bench of the Hon’ble Delhi High Court in a writ petition involving Equity Intelligence AIF Trust (the Fund) ruled that a Category III Alternative Investment Fund (AIF) shall be treated as a determinate trust insofar as the identity of the investors and their respective shares are set out in the contribution agreements
RPSG Sports Ventures Private Limited - Acquisition of a 70% equity stake in Manchester Originals Limited
Khaitan & Co advised RPSG Sports Ventures Pvt Ltd (a subsidiary of RPSG Ventures Ltd) on its acquisition of a 70% equity stake in Manchester Originals Ltd (“Manchester Originals”) from the England and Wales Cricket Board (“ECB”) for a consideration of about GBP 81.2 million.
Operational control over hotels in India creates Hyatt UAE’s ‘permanent establishment’ in India
In a landmark ruling on a foreign entity’s taxable presence in India, the Supreme Court in Hyatt International Southwest Asia Ltd. v Additional Director of Income-tax, 2025 INSC 891 held that the existence of sustained, pervasive, and enforceable control over a hotel’s strategic, operational, and financial affairs is sufficient to constitute a ‘Permanent Establishment’ (PE) of a foreign enterprise in India.
Bambrew Plant Fiber Technology Private Limited - Fund raise
Khaitan & Co advised Bambrew Plant Fiber Technology Pvt Ltd in relation to fund raise by Bambrew Plant Fiber Technology Pvt Ltd ("Company") of approximately over USD 10 million in a round led by Ashok Goel Trust and Enrission India Capital.
The Firm role includes assistance with preparation, negotiation and finalisation of transaction documents; facilitation of secondary transfers of exiting shareholders of the Company; closing assistance; and other ancillary advise to the Company in relation to the transaction.
Kandhari Global Beverages Private Limited - Acquisition of Wave Beverages Private Limited
Khaitan & Co advised Kandhari Global Beverages Pvt Ltd on the acquisition of Wave Beverages Pvt Ltd for a deal value of approx. INR 1,000 crores. Wave Beverages is the licensed bottler of Coca-Cola for certain territories in Punjab and Haryana.
The Firm role included assisting Kandhari Global Beverages Pvt Ltd on the structuring of the acquisition from regulatory and tax perspective, conducting legal due diligence on Wave Beverages Pvt Ltd, assisting with the drafting and negotiation of the transaction documents and the closing of the transaction.
Wilmar Group on its proposed acquisition of up to 20% stake in AWL Agri Business
Khaitan & Co advised the Wilmar Group on its proposed acquisition of up to 20% stake in AWL Agri Business, held by Adani Group for approximately INR 71 billion.
Sovos Compliance Limited - Acquisition of GST Application Service Provider Business from IRIS Business Services Limited
Khaitan & Co advised Sovos Compliance Ltd on acquisition of IRIS Business Services Limited’s GST Application Service Provider business through a carve-out of the business into IRIS Logix Solutions Pvt Ltd (a subsidiary of IRIS Business Services Ltd) and the subsequent acquisition of IRIS Logix Solutions Pvt Ltd. Deal closing is subject to fulfilment of Closing conditions.
The Firm advised Sovos Compliance Limited on the due diligence, structure of the transaction, drafting, negotiating, and finalisation of transaction documents, and assistance with closing.
Somic Ishikawa Inc - Acquisition of balance stake from existing joint venture partner, ZF India Private Limited
Khaitan & Co advised Somic Ishikawa Inc. in finalising agreement for acquisition of balance stake from existing joint venture partner, ZF India Pvt Ltd, making Somic ZF Components Pvt Ltd a wholly owned subsidiary of the Somic group.
The Firm acted as legal counsel to Somic Ishikawa Inc. on all legal aspects of the transaction, including: (i) negotiating, drafting, and reviewing transaction documents; (ii) conducting limited legal due diligence on Somic ZF Components Private Limited; and (iii) assisting with the execution of transaction documents.
Salesforce Ventures - Reverse flip of Razorpay
Khaitan & Co advised Salesforce Ventures on the reverse flip of fintech unicorn Razorpay, shifting its parent company's domicile from the US to India. The deal was the first to make use of India’s fast-track cross-border merger regime to complete a reverse flip.
The Firm provided advice to Salesforce Ventures in relation to (a) preservation and replication of its rights as they existed in Razorpay US pursuant to the reverse flip; and (b) tax implications on Salesforce Ventures in relation to the reverse flip.