The Indian Income Tax Department has raised concerns regarding the treaty benefits claimed by Jane Street's Singapore entity, alleging that the firm has evaded taxes on ₹8,000 crore (approximately $960 million USD) in income. This draft assessment order, sent at the end of March for the financial year 2023-24, invokes the Multilateral Instrument-Principal Purposes Test (MLI-PPT) under the India-Singapore tax treaty. The MLI-PPT allows the tax department to deny treaty benefits if it concludes that obtaining such benefits was one of the principal purposes of any arrangement. Jane Street, a high-frequency trading firm, is registered as a foreign portfolio investor (FPI) in Singapore and has been accused of using its Indian entities to influence market prices while booking profits in Singapore, where such profits are not taxed. The tax department's investigation has also considered the General Anti-Avoidance Rules (GAAR), which targets aggressive tax planning, but opted for the broader MLI provision. The scrutiny raises questions about the economic substance of Jane Street's operations in Singapore, as the firm may not have a genuine presence there. The firm has the option to appeal against the draft order through the Dispute Resolution Panel or the Commissioner of Income Tax (Appeals).