This piece examines the Income Tax Appellate Tribunal's ruling in Huntsman Investments B.V. v. ADIT, which classified a share buyback as corporate reorganisation under Article 13(5) of the India-Netherlands DTAA. It contrasts this outcome with divergent tribunal positions in Accordis Baheer, Legrand Nederland, and RBS AA Holdings, highlighting inconsistent treatment of buybacks and capital reductions despite similar factual patterns. The absence of a treaty definition for "reorganisation" has led tribunals to rely on academic sources and unrelated statutory provisions, producing unpredictable outcomes for foreign investors. The piece proposes a three-fold test, covering continuity of ownership, materiality of change, and transactional intent, drawing on UK statute and OECD guidance to standardize interpretation.