Against Vodafone: Anusha Patil

Against vodafone
by Anusha Patil - Monday, 30 March 2020, 5:59 PM

Number of replies: 0
As the justices held that there was no patent illegality in the IT depatment’s notice to
vodafone.This supports that view that the IT department may take a wider tax footprint
including in croos-border transactions outside the jurisdiction of India.
Against
by Ashwini Ramesh - Monday, 30 March 2020, 5:56 PM

Firstly, Vodafone filed a written petition in the Bombay high court, challenging in
jurisdiction of the tax authorities. Vodafone challenged the order of the Bombay high court
before supreme Court Government has no jurisdiction over vodafone's purchase of mobile
assets in India.
For Vodafone
by Hayawadan Ayachit - Monday, 30 March 2020, 5:55 PM

As per the supreme courts decision ,which says Vodafone is not liable to pay tax .court
states that ,
1)The Indian revenue authorities had no jurisdiction to tax the foreign transactions, as of
shares was in Cayman island.
2) As capital asset is not taxable in India ,so there is no question of deducting the tax at
source under section 195(1).
Its clearly seen that supreme court reversed the decision of Bombay high court.
The above case highlights the transaction between Vodafone holdings international
purchasing shares of a Cayman company CGP investments from Hutchinson
Telecommunications international Ltd for a total amount of $11 billion. CGP investments in
turn held 67% stake of Hutch essar, an Indian telecom company. The deal ultimately resulted
in the ownership of Hutch Essar by Vodafone.
Since the deal was offshore, neither party thought it was taxable in India as the sale
transaction took place in between two foreign companies .
But the income tax department had claimed capital gains under section 9(1)(i) of the income
tax act and Vodafone was asked to pay more than $1 billion and after adding penalty and
interest, the sum went up-to $2.5 billion. The claim according to me was not at all reasonable
Even the supreme courts decision was in favor of Vodafone which stated that company is not
liable to pay tax. The judgement was supported with following facts:
1) Section 9(1)(i) of the act does not have 'look through' provisions and it cannot be extended
to cover indirect transfers of capital assets/property situated in India.
2). The Indian tax authorities had no provision to tax the foreign transactions between two
foreign companies.
Accordingly, SC concluded that the transfer of the share in CGP did not result in the transfer
of a capital asset situated in India and gains from such transfer were not liable to Indian tax.
Therefore, Vodafone was completely fair in it's practice according to me.
Against Vodafone
by Kiran Dhamune - Monday, 30 March 2020, 5:55 PM

Vodafone had acquired through Vodafone International holdings which was indirect.
Complete transactions of Hutchinson and Vodafone was conducted in the Cayman islands to
ensure the minimum tax liability. Vodafone had paid $11 billion for this deal. There was no
tax paid by any of the parties. As per the taxation law of India , it was meant that they would
get away without paying any tax to the government.
It was not liked by the government of India. The government said that Hutchinson and
Vodafone was liable for tax deduction under the income tax act.
Hence the Vodafone had not deducted the tax at source for which government had to demand
more.
Against
by Karan Mane - Monday, 30 March 2020, 5:55 PM

Hutchison (Hongkong) is a Non resident having no tax implications in India. Cayman Island
(Mauritius) was a 100 % Subsidiary of Hutchison (Hongkong). Hutchison Essar was an
Indian co. in which Cayman Island(Mauritius) was holding 67 % shares and Essar had total
holding of 33 % only.
Mauritius is considered as a tax Heaven Country, So Cayman Island was incorporated for this
transaction exclusively. Vodafone is a co. incorporatedin Nederland (UK), treated as foreign
co. in India.
As per this case the Vodafone has to pay tax beacuse most of the assets were in India and
Vodafone having operational control over Indian asset..
For Vodafone
by Apurva Rajput - Monday, 30 March 2020, 5:54 PM

According to me the case relates to Vodafone entering the Indian telecom business. The tax
department demanded a heavy sum to be paid. Vodafone denied the liability. The dispute was
finally decided by the Supreme Court of India in Vodafone’s favour. The government of
India did not concede defeat and amended the taxation law retrospectively so that Vodafone’s
legal victory would convert into a political and business defeat.
Against
by Simran Sayed - Monday, 30 March 2020, 5:54 PM

Section 9 deem to be accured and arise. If an indian company shares are transferred outside
india than the foreign company has to pay tax to indian government.
Hutchessar is an indian company whose 68% shares are with CGP which is an non residential
company situated in foreign and CGP'S 100 % shares are with hutchson which is an
hongkong based company. So hutchson sold its 100% share of CGP to vodafone a netherland
based company. So the new retrospective law says that any company which is derives its
share value from indian basied company than it should pay tax to the indian government.
For Vodafone
by Naveen Naveen - Monday, 30 March 2020, 5:53 PM

1.It has no presence in India at the time of transfer of share.

2.The transaction was consummated outside India.
3.The government law of contract pursuant to which it was transferred was English law.
4. Payment was made from bank account outside India there is no deduction of tax of such
payment
5.This strategy was used by both the companies to avoid tax payment to the Government of
India.
6.The Government then filed a case against vodafone and won,but lost in Supreme Court
after Vodafone filed for SLP.
7.The favourable point for vodafone was transfer of share in CGP did not result in transfer of
Capital Asset suitated in india and such gains were not subject to Income Tax.
8.There was however amended to the IT Act to avoid such losses.
9.All Vodafone Telecom did at that time was "Unethical" and "Not illegal"
For Vodafone
by Tushar Bharamgonda - Monday, 30 March 2020, 5:50 PM

The case is all about vodafone's attempt to avoid paying the taxes. Vodafone Holdings
International (“Vodafone”), a Dutch company, purchased shares of a
Cayman Company–CGP Investments (Holdings) Ltd from a foreign company Hutchinson

Telecommunications International Limited–HTIL for a total consideration of $11.2 billion.
CGP Investments in turn held 67% stake of an Indian Telecom company (Hutch Essar)
through intermediate companies situated in Mauritius.'section 9(1) The following incomes
shall be deemed to accrue or arise in India;
-all income accruing or arising.weather directly or indirectly,through or from any other

business connection in India,or through pr from any property in India,or through or from any
assetr or source of income in India ,or through the transfer of a capital asset situate in India.
For
by Saniya Quadri - Monday, 30 March 2020, 5:47 PM

If today you buy 10% of shares of particular company let us say jet airways, does this mean
that you automatically own 10% of all the jet airways assets. Does this mean 10% of entire
fleet of aircraft now belongs to you? By buying out a company that holds 67% of HEL., It
sdoes not mean that vodafone now owns 67% of the assets of HEL
For vodafone
by Anup Yankati - Monday, 30 March 2020, 5:47 PM

Firstly Vodafone company thought of purchasing the Hutchison Essar Limited of India in
55000 crores. But then they got to know that Hutch company had already established a
intermediate company in Cayman Islands named CGP investment holding and it's parent
company was in Hong Kong named Hutchison telecommunications international limited
(HTlL).
CGP investment holding had already 67% shares of Hutchison Essar Limited so Vodafone
thought of purchasinlets see what ''look through'' provision say
-section 9 of the ''income tax act 1961'' provided for ' look through' and what mean 'in
consequence of' as follows
''section 9(1) The following incomes shall be deemed to accrue or arise in India;
-all income accruing or arising.weather directly or indirectly,through or from any other

business connection in India,or through pr from any property in India,or through or from any
assetr or source of income in India ,or through the transfer of a capital asset situate in India.g
these shares of HEL instead of purchasing the company.
Against vodafone
by Shreya Kapase - Monday, 30 March 2020, 5:45 PM

The Petitioner- the assessee- Vodafone purchased shares of a foreign company based in
Cayman Islands which in turn held shares of an Indian company Hutch Essar from another
foreign company (HTIL). The Respondent- the Assessing Officer, issued a show cause notice
asking the assessee why it should not be treated as an assessee in default (AID) for its failure
to withhold taxes at source and credit the same to the Central Government on the transaction
in issue. The assessee challenged the said Show Cause Notice on the ground that the
transaction in issue was a simple transfer of shares between two foreign companies and not
transfer of any capital asset in India and as such, said transaction did not attract the provisions
of Income Tax Act.
Question of law involved: Whether the transfer of shares between two foreign companies,
resulting in extinguishment of controlling interest in the Indian Company held by a foreign
company to another foreign company, amounted to transfer of capital assets in India and as
such chargeable to tax in India.
Transaction amounting to transfer of capital assets in India, by divestment of controlling

stake in an Indian Company held by a foreign company to another foreign company resulting
in extinguishment of right, would attract provisions of Indian Income Tax Act.
Any profit or gain which arose from the transfer of a group company in India has to be
regarded as a profit and gains of the entity or the company which actually controls its,
particularly when on facts, the flow of income or gain can be established to such controlling
company and as such is taxable in India.
For vodafone
by Dhanashree Chougule - Monday, 30 March 2020, 5:43 PM

Firstly, Vodafone filed a written petition in the Bombay high court, challenging in
jurisdiction of the tax authorities.
Vodafone challenged the order of the Bombay high court before supreme Court
Government has no jurisdiction over vodafone's purchase of mobile assets in India.
For Vodafone
by Pakshal Mehta - Monday, 30 March 2020, 5:42 PM

The above case highlights the transaction between Vodafone holdings international
purchasing shares of a Cayman company CGP investments from Hutchison
Telecommunications international Ltd for a total amount of $11 billion. CGP investments in
turn held 67% stake of Hutch essar, an indian telecom company. The deal ultimately resulted
in the ownership of Hutch Essar by Vodafone. Since the deal was offshore, neither party
thought it was taxable in india as the sale transaction took place in between two foreign
companies. But the income tax department had claimed capital gains under section 9(1)(i) of
the income tax act and vodafone was asked to pay more than $1 billion and after adding
penalty and interest, the sum went upto $2.5 billion. The claim according to me was not at all
right.
Even the supreme courts decision was in favour of Vodafone which stated that company is
not liable to pay tax. The judgement was supported with following facts:
1) Section 9(1)(i) of the act does not have 'look through' provisions and it cannot be extended
to cover indirect transfers of capital assets/property situated in india.
2). The indian tax authorities had no provision to tax the foreign transactions between two
foreign companies.
Accordingly, SC concluded that the transfer of the share in CGP did not result in the transfer
of a capital asset situated in india and gains from such transfer were not liable to indian tax.
Therefore, vodafone was completely fair in it's practice according to me.
against VODAPHONE
by saniya bhaldar - Monday, 30 March 2020, 5:39 PM

In this case two issues are involved :
i. Taxability of the transaction. Paragraphs II.1 to II.18
ii. Vodafone’s liability to deduct tax at source. Paragraph II.19
In our submission, the income is taxable in India and Vodafone is liable to deduct tax at
source. For failing in its duty to deduct the tax – despite advance warnings, Government is
entitled to proceed against Vodafone.
Since Honourable Supreme Court (SC) has decided differently, today the law prevalent in
India is that the income is not taxable and hence Vodafone is not liable to deduct the tax at
source. In our humble submission, with respect to the Honourable Supreme Court, the
decision is incorrect. Income is taxable & hence Vodafone is liable to deduct tax at source.
This is a fit case for retrospective amendment in law. Not doing so has serious consequences.
Wide scale aggressive tax avoidance through tax havens and their approval by honourable SC
creates a risk of equally wide & harsh tax provisions. These will affect all: aggressive tax
planners as well as honest tax payers.
We are personally against Retrospective Amendments. Normally, a retrospective amendment

means injustice. However, the present case is an open and massive abuse of law. Honourable
SC has, in our humble submission, not given justice to India and to Indians. This is a fit case
for retrospective amendment.
It is possible that Honourable SC Justices could have considered the consequences on FDI
and given such a decision. Not realising that this compromise in law can open up flood gates
of abuse of law.
Against Vodafone
by Omkar Dongre - Monday, 30 March 2020, 5:38 PM

Facts of the Case: Hutchison (Hongkong) is a Non resident having no tax implications in
India. Cayman Island (Mauritius) was a 100 % Subsidiary of Hutchison (Hongkong).
Hutchison Essar was an Indian co. in which Cayman Island(Mauritius) was holding 67 %
shares and Essar had total holding of 33 % only.
Mauritius is considered as a tax Heaven Country, So Cayman Island was incorporated for this
transaction exclusively. Vodafone is a co. incorporatedin Nederland (UK), treated as foreign
co. in India.
Few Questions which are still unanswered:Does asking a non-resident to comply with Indian
legal procedures amount to ExtraTerritorial Jurisdiction Can a company merely having a
incorporation certificate of a tax heaven country and a few files in its office, should be
allowed to evade taxes by various methods
Against vodafone
by Nagaratna Marihal - Monday, 30 March 2020, 5:38 PM

The IT department’s argument was based on Section 9 (1) (i) of the ITA that said, “all
income accruing or arising, whether directly or indirectly, through or from any business
connection in India, or through or from any property in India, or through or from any asset or
source of income in India or through the transfer of a capital asset situate in India."
In 2007, Vodafone indirectly acquired through Vodafone International Holdings BV –
a Dutch entity, the complete share capital in CGP which controlled 67 per cent of an Indian
company Hutchison Essar Limited.
The dispute is about the vodafone not ready to pay the tax.
The Vodafone company running its business in India by using the assets of India. According
to the Indian tax policies each and every firms in Indian are liable to pay the tax for the
income earned in the country. But in this case the company was not ready to pay the tax fixed
by the government and this is opposite to the government.
AGAINST VODAPHONE
by saniya bhaldar - Monday, 30 March 2020, 5:36 PM

In this case two issues are involved :
i. Taxability of the transaction. Paragraphs II.1 to II.18
ii. Vodafone’s liability to deduct tax at source. Paragraph II.19
In our submission, the income is taxable in India and Vodafone is liable to deduct tax at
source. For failing in its duty to deduct the tax – despite advance warnings, Government is
entitled to proceed against Vodafone.
Since Honourable Supreme Court (SC) has decided differently, today the law prevalent in
India is that the income is not taxable and hence Vodafone is not liable to deduct the tax at
source. In our humble submission, with respect to the Honourable Supreme Court, the
decision is incorrect. Income is taxable & hence Vodafone is liable to deduct tax at source.
This is a fit case for retrospective amendment in law. Not doing so has serious consequences.
Wide scale aggressive tax avoidance through tax havens and their approval by honourable SC
creates a risk of equally wide & harsh tax provisions. These will affect all: aggressive tax
planners as well as honest tax payers.
We are personally against Retrospective Amendments. Normally, a retrospective amendment

means injustice. However, the present case is an open and massive abuse of law. Honourable
SC has, in our humble submission, not given justice to India and to Indians. This is a fit case
for retrospective amendment.
It is possible that Honourable SC Justices could have considered the consequences on FDI
and given such a decision. Not realising that this compromise in law can open up flood gates
of abuse of law.
Against
by Akshata Bagadi - Monday, 30 March 2020, 5:33 PM

1. According to tweets on social media, the problem seems to have affected users in
Karnataka the most.
2. Vodafone's network failure is suspected to be because of BBMP's drive to remove optical

fiber cable in the city
3. '#Vodafonedown' is trending on Twitter today. The telco's network is reportedly down in

Bangalore and other areas.
4. Vodafone users have reported problems in sending and receiving calls, messages, data.
5. Users from Mumbai, jharkhand and other places have also made similar complaints.
6. BBMP had reportedly given telco's six weeks, until 7 Feb 2020 to remove OFC's above the
ground and take them underground.
Against Vodafone
by Shriya Chiniwalar - Monday, 30 March 2020, 5:33 PM

Vodafone entered India through an subsidiary based in Netherlands which acquired the joint
venture which was held and operated in the telecom license situated in India.The tax
department demanded to showcase and an issue was been sent to Vodafone to show it's
reasons that why it didn't deduct it's capital gains while making the payments.The transaction
between Hutchison and Vodafone was conducted in the Cayman Islands to ensure minimum
tax liability on either of them. Vodafone paid about $ 11 billion for this deal. Nothing was
paid by any of the parties as capital gains tax.
But as per the Indian law Vodafone should have paid the taxes. Vodafone said that wasn't
intentional but that is against the law.
The government of India lost it's case in the supreme court by which it was not convinced. It's
the mistake of Vodafone company and it should have paid the taxes according to the law.
Against
by Nikhil Rao - Monday, 30 March 2020, 5:33 PM

The Supreme Court of India after hearing the matter for over two months, has delivered its
much awaited landmark 275-page decision, involving taxability of a transaction between two
non-resident companies (having no presence in India), in relation to transfer of shares of an
overseas company, in favour of Vodafone International BV (VIH) to hold that the transaction
is not taxable in India and also that the Revenue Authorities (RA) have no jurisdiction to tax
the transaction. The SC has also provided observations and decisions on various domestic and
international tax issues/principles which could have significant ramifications. After deciding
the case in favour of VIH, the SC has also directed the RA to refund INR 25 billion deposited
by VIH (following SC directions) with interest @ 4% p.a. within two months from the date of
this decision. The Vodafone controversy which had created a lot of uncertainty for
multinationals having similar structures and/or which had entered into or were proposing to
enter into similar transactions, and thus, this should provide the much needed respite to these
litigants.
Against Vodafone
by Manjunath Bhat - Monday, 30 March 2020, 5:31 PM

The case relates to Vodafone entering the Indian telecom business. The tax department
demanded a heavy sum to be paid. Vodafone denied the liability. The dispute was finally
decided by the Supreme Court of India in Vodafone’s favour. The government of India did
not concede defeat and amended the taxation law retrospectively so that Vodafone’s legal
victory would convert into a political and business defeat.
The Vodafone- a mobile company decided to enter the Indian telecom market in 2017. The
company registered in the Cayman Island. And the island was tax heaven - which controlled
67% of an Indian company Hutchison Essar ltd. The Vodafone paid about $11 billion for this
deal. Not even single penny was paid by any of the parties as capital gain tax.
Mr P Chidambaram was the Finance Minister at that point of time. The tax department
demanded its pound of flash and a show -cause notice was issued to Vodafone to explain why
id did not deduct the capital gain tax while making the payment. Vodafone was asked to pay
to the tax department more than $1 billion and after adding penalty and interest the sum was
even more than $ 2.5 billion.
Vodafone filed the case in the Bombay high court and the court held that as the assets were
in India the and Vodafone was liable to pay. after hearing the judgement of High court of
Bombay the Vodafone challenged this case in the supreme court of India.
The court explained the basic international taxation and why foreign investors willing to
invest India. The reasons given by the supreme court is different from those given by the
Bombay high court. The supreme court also dealt with the argument of tax department that
section 9 'look through'. And concluded that this section did not have 'look through'.
The government of India was extremely embarrassed and after some time it had decided to
amend the relevant law. After some time Mr Pranad Mukharjee became the Finance Minister
and he said the " it cannot be the someone will make money on asset in India and not pay tax
in India, if they are entitled then India is surely entitled, India is not inferior to anyone. And
he also said that " The supreme court may interpret law but parliament has the ability to make
amendments to law to correct court's judgement.
The Vodafone company running its business in India by using the assets of India. According
to the Indian tax policies each and every firms in Indian are liable to pay the tax for the
income earned in the country. But in this case the company was not ready to pay the tax fixed
by the government and this is opposite to the government.
Vodafone case study
by Samantha Dharamdasani - Monday, 30 March 2020, 5:28 PM

Vodafone Idea Ltd. took a one-time charge that led to a net loss of ₹50,900 crore loss in the
three months through September
The company’s ability to continue as going concern is dependent on obtaining the reliefs
from the government," Vodafone Idea said in a statement late Thursday. It is “in active
discussions with the government seeking financial relief," it said.
“If you don’t get the remedies being suggested, the situation is critical," Vodafone CEO Read
said on Nov. 12. “If you’re not a going concern, you’re moving into a liquidation scenario
can’t get any clearer than that."
Against Vodafone
by Rahul Patil - Monday, 30 March 2020, 5:23 PM

The case is all about vodafone's attempt to avoid paying the taxes. Vodafone Holdings
International (“Vodafone”), a Dutch company, purchased shares of a
Cayman Company–CGP Investments (Holdings) Ltd from a foreign company Hutchinson

Telecommunications International Limited–HTIL for a total consideration of $11.2 billion.
CGP Investments in turn held 67% stake of an Indian Telecom company (Hutch Essar)
through intermediate companies situated in Mauritius.
And on the bases of case Vodafone has to pay tax because most of the assets were in India,
the deal was liable to Indain Capital gains tax. Hutch had sold vodafone valuable rights
including tag along rights, management rights and the right to do business in India and that
the Vodafone having operational control over the Indian asset, so Vodafone is liable to pay
tax...
Vodafone case study
by Aishwarya Kolkar - Monday, 30 March 2020, 5:23 PM

2007 Vodafone International Holdings BV decided to expand its footprint in the Indian
mobile phone market by buying out Hutchison Essar. The transaction between was conducted
in Cayman island to avoid tax liability on them . Indain government didn't liked this issued a
notice against Vodafone
The government has no jurisdiction over Vodafone’s purchase of mobile assets in India as the
transaction took place in Cayman Islandsbetween HTIL & Vodafone.” Chief Justice S.H.
Kapadia said.
The Income Tax department can file a review petition on the Supreme Court’s judgement.
Technically the government can go in for a reviewbut I do not think this is a fit case for that
because extensive hearings have already taken place.
For Vodafone
by Sumesh Ghatkamble - Monday, 30 March 2020, 5:20 PM
The case is all about Vodafone entering the Indian Telecom business . And tax issue .
The tax department of India demanded heavy sum from Vodafone company , but
company refused to pay , so they failed a case , supreme Court of India gave decision in
Vodafone favour because
• Indian revenue authorities had no jurisdiction to tax the foreign transaction
•. Capital assets is not taxable in India so there is no question of asking taX
Against Vodafone Against the topic
Against Vodafone
by Padmanabh Bhat - Monday, 30 March 2020, 4:52 PM

A decade ago in 2007, Vodafone International Holdings BV forayed into the Indian mobile
phone market by buying 52% stake in Hutchison Essar.
However, the company’s subsidiary exchanged cash for shares with a similar holding
company for Hutchison Essar, in far off Cayman Islands. At the time, Indian tax authorities
did not have a say in the company’s doings as the deal was done entirely offshore
In 2012, Vodafone had first initiated arbitration against the government invoking the India-
Netherlands Bilateral Investment Protection Agreement (BIPA). The Apex Court of India
ruled in favour of Vodafone by saying it acted ‘within the four corners of law’.
The IT department’s argument was based on Section 9 (1) (i) of the ITA that said, “all
income accruing or arising, whether directly or indirectly, through or from any business
source of income in India or through the transfer of a capital asset situate in India."
The Indian government saw over Rs 20,000 crore in unpaid taxes by Vodafone, a report by
the Hindu pointed out in 2014.
The government then came up with the General Anti-Avoidance Rule (GAAR). This rule
basically said that the government could dig up past deals, all the way back to 1962. GAAR
was postponed to 2016.
Despite winning the $2 billion tax case in the Supreme Court five years ago, the matter was
picked up by the Delhi High Court this year.
On August 22, the High Court had restrained Vodafone Group’s arbitration proceedings
under the India-UK BIPA. This was the company’s second arbitration on the same issue, as
per a PTI report.
The government challenged the second arbitration as well stating 'the two claims were based
on the same cause of action and seek identical reliefs but from two different tribunals
constituted under two different investment treaties against the same host state'.
Vodafone, however, told the court it would not submit to the jurisdiction of the court in
relation to the Rs 11,000 crore tax demand.
At the end of October 2017, the HC allowed Vodafone Group representatives to participate in
the process of appointing a presiding arbitrator in its international arbitration process against
India in the tax dispute case.
What lies at stake here are Vodafone’s profit margins and reputation. Even though the matter
is still in court, it is important to know whether a company is paying its dues to the
government.
For the topic
by sneha malkari - Monday, 30 March 2020, 4:52 PM

Vodafone Idea’s estimated outgo of about ₹40,000 crore is far in excess of its cash balance of
around ₹20,000 crore. Supreme Court which is setting a three-month deadline for the
payment of the dues, hardly any investors were willing to bet that the company would
survive. Its shares fell to below ₹4 per share, and tellingly, stocks of banks such as State
Bank of India fell sharply as well. Most of the dues owed to the government as a result of the
Supreme Court order were from firms which were already bankrupt or are now facing
bankruptcy. So it isn’t surprising that the government has moved relatively quickly since the
SC ruling. It has set up a committee of secretaries (CoS) to suggest ways to alleviate the
stress being faced by the telecom sector .
Vodafone Idea fell 5.34% to Rs 6.92 at close on the BSE Friday. Besides, if consumers have
been willing to pay higher prices for nearly all goods and services as a result of inflation,
what separates this industry that its tariffs only head downward.Despite being one amongst
the largest ruler of telecom sector Vodafone avoided to deploy crash landing in Indian market
.
In sum, encouraging ultra-low prices may look like a pro-consumer move now, but if this
results in a monopoly situation, it can quickly turn anti-consumer. To start with, it makes
sense for the government to ask CCI to weigh in on the concerns about pricing and give its
recommendations. Government would however discourage monopoly segment in such
sectors and the decision hampered its market itself . Vodafone’s merger was remarkable for
short term growth.
For Vodafone
by Sarvesh Majati - Monday, 30 March 2020, 4:49 PM

(1)As per the taxation law,even when the assets involved in the offshore deal were located in
India,they could get away without paying any tax to the government of India.
(2)There was lack of clarity and absence of appropriate provisions in the law regarding the
situation in which the judicial anti avoidance rules would apply.
(3) Vodafone had entered into the deal into the deal not to avoid taxes but it had a investment
view and it wanted to participate in the Telecom sector of the Indian market.There is a
conceptual difference between the transaction which is created for tax avoidance purposes,on
the one hand and a transaction which evidences investment to participate in India.
(4) Vodafone is not at fault as they were of the view that the compliance of the law in letter
was more than enough and that was the only thing which was expected from them.
(5) Vodafone should not be made to pay taxes as the supreme Court had ruled in it's favor
saying Indian authorities have no jurisdiction over the offshore transactions.
(6)In this case the government seems to be losing revenue and due to that they want to amend
the law and make Vodafone pay capital gain tax.I think it is completely unethical as
Vodafone was fully aware about the tax laws in the country and had complied with them.The
deal had also taken place when there was no clarity regarding this law.If the Government of
India amend the tax laws and make the company pay taxes,it would not be fair for
Vodafone.It would also hamper the international investors view towards our country and they
would divest their investments.
For Vodafone
by Divya Palankar - Monday, 30 March 2020, 4:47 PM

1. Vodafone decision has adverse impact on larger public interest. This consequence has been
has been ignored by court
2. Vodafone and Indian Telecom industry they both made joint venture with Hutchison Essar
Ltd when sells its property they have to pay CGT to government through legally
3. Entire transaction of sale of CGP by HTIL to VIH was in capital assets in India
4. It essential that the transaction should have some economic or commercial substance in
order to be effective
5. The tax does not necessarily lead to assumptions of evasion of taxes
Against Vodafone
by Mitali Nevagi - Monday, 30 March 2020, 4:43 PM

Vodagone played a very smart game to avoid tax by opening a intermediary company CGP
located at Cayman Islands instead of Hutch Essar which comes under CGP. The tax
authorities passed an order that they had jurisdiction to procees against Vodafone for failure
to deduct tax.
Government of India lost there case in Supreme Court of India by which the government was
not convinced.
There is no way to avoid tax in India according to law. Vodafone should have paid tax.
Against
by gurunath Shiroorkar - Monday, 30 March 2020, 4:41 PM

In 2007, Vodafone indirectly acquired through Vodafone International Holdings.
The entire transaction between Hutchison and Vodafone was conducted in the Cayman
Islands to ensure minimum tax liability on either of them. Vodafone paid about $11 billion
for this deal. Not even a single penny was paid by any of the parties as capital gains tax. As
per the taxation law of India applicable at that point of time, the parties followed the law in
letter, however, it meant that even when the assets involved in the deal were located in India,
they could get away without paying any tax to the government of India.
Obviously, the government of India did not like this.
The government had said then, that the Hutchison-Vodafone deal was liable for tax deduction
at source(TDS) under the Income Tax(IT) Act, and since Vodafone had not deducted the tax
at source, the government raised the demand.
Against
by Pearl Colaco - Monday, 30 March 2020, 4:39 PM

Vodafone was embroiled in a $2.5 billion tax dispute over its purchase of Hutchison Essar
Telecom services in April 2007. The transaction involved purchase of assets of an Indian
Company, and therefore the transaction, or part thereof was liable to be taxed in India as per
the allegations of tax department.
Vodafone Group entered India in 2007 through a subsidiary based in the Netherlands, which
acquired Hutchison Telecommunications International Ltd’s (HTIL) stake in Hutchison Essar
Ltd (HEL)—the joint venture that held and operated telecom licences in India. This
agreement gave Vodafone control over 67% of HEL and extinguished Hong Kong-based
Hutchison’s rights of control in India, a deal that cost the world’s largest telco $11.2 billion at
the time.The crux of the dispute had been whether or not the Indian Income Tax Department
has jurisdiction over the transaction.
In January 2012, the Supreme Court passed the judgement in favour of Vodafone, saying that
the Indian Income tax department had "no jurisdiction" to levy tax on overseas transaction
between companies incorporated outside India.
Government changed its Income Tax Act retrospectively and made sure that any company, in
similar circumstances, is not able to avoid tax by operating out of tax-havens like Cayman
Islands or Lichtenstein. In May 2012, Indian authorities confirmed that they were going to
charge Vodafone about 20000 crore (US $4.5 billion) in tax and fines.Retrospective Taxation
means nothing but the old proceedings are being taxed as per the new rules.
Against Vodafone
by Vishwanath Kengnal - Monday, 30 March 2020, 4:37 PM

It was an offshore deal where Vodafone Netherlands acquired ownership of a Cayman Island
based entity called CGP Investments from a Hutch group entity also based in Cayman Island.
So, while optically it was a pure offshore transaction between two non-resident entities
(Vodafone and Hutchison) and they bought and sold shares of another non-resident entity
(CGP), the Indian tax authorities took a position that by virtue of such an offshore deal, in
effect and in substance, the parties have really sold stake in the Indian telecom business of
Hutchison Essar. Therefore, they argued that profits realised from the indirect transfer of an
Indian asset (telecom business in India) was taxable in the country and therefore, the buyer
should have deducted applicable withholding tax while making payment of the purchase price
of this business.
Vadafone case study
by Raghotam Chimmalagi - Monday, 30 March 2020, 4:36 PM

Even though the Vodafone-Hutch deal was offshore, it was taxable as the underlying asset
was in India and so it pointed out that the capital asset; that is the Hutch-Essar or now
Vodafone-Essar joint venture is situated here and was central to the valuation of the offshore
shares; that through the sale of offshore shares, Hutch had sold Vodafone valuable rights - in
that the Indian asset including tag along rights, management rights and the right to do
business in India and that the offshore transaction had resulted in Vodafone having
operational control over that Indian asset. The Department also argued that the withholding
tax liability always existed and the amendment was just a clarification.
Against Vodafone
by Vijaylaxmi Deyannavar - Monday, 30 March 2020, 4:35 PM

In 2007, Vodafone indirectly acquired through Vodafone International Holdings BV –

a Dutch entity, the complete share capital in CGP which controlled 67 per cent of an Indian
company Hutchison Essar Limited. As per the taxation law of India applicable at that point of
time, the parties followed the law in letter, however it meant that even when the assets
involved in the deal were located in India, they could get away without paying any tax to the
government of India. The tax department demanded its pound of flesh and a show-cause
notice was issued to Vodafone to explain as to why it did not deduct the capital gains tax
while making the payment. It was Vodafone's fault if it did not do that.
For the Topic
by Saakshi Rajput - Monday, 30 March 2020, 4:34 PM

Since, the Indian Telecommunication Sector was at a boom, Vodafone which is a British
Mobile Company decided to enter the Indian Telecom Market in 2007.
And like every other individual or industry, Vodafone too wanted to escape heavy taxes by
the Indian Tax Authorities & the Indian Government.
So, Vodafone purchased Hutch, which already had an intermediate company i.e CGP
Investments Holdings based in the Cayman Islands, which happens to be a Tax Haven island,
whose parent company was an Indian Company and held a 67% share capital.
And, someone who makes money on an asset in India cannot elope from paying taxes to the
Indian Government.
But, the Tax Laws were not very clear with regards to such a situation. So, Vodafone took
advantage of it and started its business in India. Sooner, the Tax Laws were Amended and
anybody who made money in India had to pay taxes to the Indian Government.
Conclusion - Like any other company, Vodafone too wanted to expand its business and add
its profits. It was the unclear Tax Laws that led to the confrontations between Vodafone and
Indian Government.
Thank You.
Against Vodafone
by Neha Hundre - Monday, 30 March 2020, 4:32 PM

The tax authorities arguments were focused on proving that even though the deal had taken
place overseas, the transaction was not merely a transfer of a single share but a composite of
rights and entitlements of local assets making the transaction taxable in India. The underlying
asset i.e. the joint venture, as asset of capital nature, was situated in India and was central to
the valuation of shares. It was through the transfer of overseas shares, HTIL sold its rights in
the Indian asset including the tag along with the rights, managements rights, goodwill, brand
and the right to do business in India.
The offshore transfer resulted in Vodafone having operational control over the Indian asset
and Vodafone also entered into separate agreements with the Indian entities to conduct
business in India.Hence,they should be liable to pay tax to Indian government.
For Vodafone
by Omkar Patil - Monday, 30 March 2020, 4:32 PM

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Against vodafone
by Anjana Gadagalli - Monday, 30 March 2020, 4:30 PM

The entire
transaction between Hutchison and Vodafone was conducted in the Cayman Islands to
ensure minimum tax liability on either of them. Vodafone paid about $ 11 billion for this
deal. Not even a single penny was paid by any of the parties as capital gains tax. As per the
taxation law of India applicable at that point of time, the parties followed the law in letter,
however, it meant that even when the assets involved in the deal were located in India, they
could get away without paying any tax to the government of India.
Against Vodafone
by Amit Paripattedar - Monday, 30 March 2020, 4:26 PM

The tax department demanded its pound of flesh and a show- cause notice was issued to
Vodafone to explain as to why it did not deduct the capital gains tax while making the
payment. It was Vodafone's fault if it did not do that. And for Vodafone's fault why should
government suffer? So the Vodafone was asked to pay to the tax department more than $1-
billion and after adding penalty and interest, the sum was even more than $2.5 billion.
Finding itself cornered and with no option left , Vodafone decided to challenge this order
in a proper judicial forum.
Against
by Rishita Rajput - Monday, 30 March 2020, 4:25 PM

Vodafone entered India through an subsidiary based in Netherlands which acquired the joint
venture which was held and operated in the telecom license situated in India.The tax
department demanded to showcase and an issue was been sent to Vodafone to show it's
reasons that why it didn't deduct it's capital gains while making the payments. It was the
mistake of Vodafone that it completely neglected to do so. Because of the mistake which
Vodafone had made it wasn't required the Government to face it, hence Vodafone was been
asked to pay to the tax department a sum of more than $1 Billion. And after adding up the
penalty and fines the sum was increased to more than $2.5 Billion
For vodafone
by Dixita Savant - Monday, 30 March 2020, 4:16 PM

Vodafone a British mobile company and entered India telecom market in 2007 Cayman
has acquired 67 % shares in Hutchison Essarinitially, Hutchison (Hongkong) has sold
Cayman Island to Vodafone (UK) @ $ 11billion and Vodafone has paid entire sum to
Hutchison (Hongkong) without deducting any TDS. Hutchison has sold shares of Indian co.
in form of Cayman Island to Vodafone UK. But by this method they have saved capital gain
taxes (Ought to be arisen in India) on such Transaction. TDS. Then vodafone payed more
than $1billion and also payed penalty and interest. Governement did not lose hope and tried
to bring amendment in the current polices so that companies like Vodafone should not
intentionally avoid taxes for their benefits.
As per The supreme court's Decision
Supreme Court’s held ruling to set aside the Bombay High Court judgement asking the
company to pay income tax of INR 11,000 crore.
The court also asked the IT department to return Rs 2,500 crore deposited by Vodafone, in
compliance of its interim order, within two months along with 4 per cent interest.
“The government has no jurisdiction over Vodafone’s purchase of mobile assets in India as
the transaction took place in Cayman Islands between HTIL & Vodafone.” Chief Justice S.H.
Kapadia said.
Against Vodafone
by Vinanti Majukar - Monday, 30 March 2020, 4:14 PM

The transaction between Hutchison and Vodafone was conducted in the Cayman Islands
to ensure minimum tax liability on either of them. Vodafone paid about $ 11 billion for
this deal. Not even a single penny was paid by any of the parties as capital gains. Vodafone
was asked to pay to the tax department more than $ 1 billion and after adding penalty and
interest, the sum was even more than $ 2.5 billion. It filed a case in Bombay high court but it
not not in their favour. Later they filed a case in supreme court and the judgement was in
their favour.
As Mr. Pranab Mukherjee rightly said “It cannot be that someone will make money on an
asset in India and not pay tax in India or in its country of origin,” Mukherjee said during the
debate on the finance bill in the Lok Sabha today. Later……Mukherjee said Britain, too,
allowed taxes to be levied retrospectively.
“If they are entitled, then India is surely entitled. India is not inferior to anyone. We cannot be
a tax haven just to attract foreign investment,” he said. Mukherjee also made it clear that he
did not think it was unusual to make clarificatory amendments on the basis of court
judgments.
Drawing on his formidable knowledge of constitutional law, the minister pointed out that the
first amendment made by Parliament in 1951 to the Constitution was on the basis of a
Supreme Court judgment, which sought clarifications of legislative intent.
“The Supreme Court may interpret law but Parliament has the ability to make amendments
to law to correct Supreme Court’s judgment,” he said.
“By interpretation of law our ability of amending law is not taken away,” he added.
Vodafone company has to pay the capital gain tax because all it's action were just to avoid
tax. The government also said that the company should not intentionally avoid tax payings.
For vodafone
by Pooja Koliwad - Monday, 30 March 2020, 4:14 PM

A company being bought or sold taxes are compulsory. But, Indian Acts did not specify
about the foreign transactions. Due to foreign exchange Hutch had to pay the charges for the
shares it had and sold. Ultimately, when they sold the company they did not pay the amount
to India. Indian government caught hold of Vodafone who had bought the company with
their name.
The problem would not have arised if Indian law was clear with Foreign business dealings. IT
had no legal right to charge taxon overseas. Thus, Vodafone Essar officially rebranded the
"Hutch" brand to "Vodafone" in India
For vodafone
by Vishal Asangi - Monday, 30 March 2020, 4:05 PM

The vodafone company entered into indian market in 2007 and after that they planned to
purchase the Hutchison Essar limited (HEL) for 55000 crores.which has already set up in
india to avoid tax burden's Vodafone didn't purchased the hutch company which was located
in India to avoide TCS and TDS instead buying Hutch company in india the vodafone
company purchased the intermediate company Which was located in cayman iceland called.
CGP Investment company with 67% of shares which means vodafone indirectly purchased
Hutchison Essar limited and vodafone replaced Hutchison limited from india.in this whole
transaction an Indian company was purchased and sold so the income tax department of india
told vodafone to pay the tax . vodafone said that we are not purchased the Hutchison Essar
limited,we purchased CGP Investment company which is held in cayman iceland therefore
vodafone india refused to pay the tax because legally they don't have to pay the tax after that
indian government file the case against vodafone in bombay highcourt ,the highcourt
declared that vodafone has to pay the TDS. India government win the case on 3 December
2008 and court orders vodafone to pay 25,000 million in three weeks.vodafone paid the
money to indian government.after that vodafone challenged this case in suprim court
in,January 2008 indian government loose the case by the laws of that time it was a loop hole
that several company's did.. suprim court orders income tax department that don't have any
authority to charge tax on overseas transactions the court orders the indian government to
return 25000 million Euros with 4% internet..the vodafone india won the case and received
there money as well.
Against
by Darshan Wali - Monday, 30 March 2020, 4:03 PM

Vodafone enterd Indian Market by indirectly acquiring the complete share capital in CGP-A
company in Cayman island which controlled 76% of Indian Company . Vodafone made a
deal of $11 billion with Hutchison Group Ltd ( A joint Venture between Essar group from
India and Hutchison Group from Hong Kong
And on the bases of the case Vodafone has to pay tax for using Indian asset. As Vodafone
creates it's revenue in India it have to pay the tax to creating it's assets in India. Hutchison
was taxable in India before, so Vodafone is liable to tax.
For Vodafone
by Manikant Goni - Monday, 30 March 2020, 4:03 PM

1. Vodafone had three clear objectives those are:raise their brand visibility, position them as a
B2B thought leader, and generate more sales opportunities
2. Vodafone believes in creating long term partnerships with its suppliers in order to achieve
this. My committing to buying large volume over a number of years Vodafone can negotiate
lower price this also remuneration the supplier because they enjoy the greater security of
having guaranteed orders. Vodafone lunch the new product and technology for the
developing country in order to provide cheaper network communication system to those
people
For Vodafone
by Rushikesh Verlekar - Monday, 30 March 2020, 4:01 PM

1. Vodafone Telecom company looking forward to start a business in india purchased an

intermediate company at Caymans Island knows as 'CGP Investment Holding' which holded
67% share of Hutch Essar, India.
2. Case is about Vodafone entering Indian Telecom industry and they made joint venture with
Hutchison essar Ltd company which is indian company .legally when when sells it's property
they have to pay CGT to government.
3. They need not pay tax as they didn't purchased the company but they purchased the Share
of others company so they aren't liable to pay tax.
For Vodafone
by Keerti Koli - Monday, 30 March 2020, 3:58 PM

✓ Vodafone decided to challenge this order in a proper judicial forum. India is a country
committed to the rule of law and providing opportunity to foreigners and foreign companies
to seek legal remedies in Indian courts, was respected all over the world for its fearless and
independent judiciary.
✓ Vodafone has threatened to take India to international arbitration over

planned retrospective tax legislation , it had served the Indian government with a "notice
of dispute" in a first step toward international arbitration. And it argued that the new Indian
tax legislation was an attempt to bypass a ruling by the country's Supreme Court in January
that Vodafone was not liable for taxes and penalties of up to $4.4bn.
✓ To retroactively tax overseas mergers would "countermand" the court verdict and
"violates international legal protections granted to Vodafone and other international investors
in India", Vodafone added in a statement. The notice was served by Vodafone's Dutch
subsidiary.
For the topic
by Preeti Shinde - Monday, 30 March 2020, 3:58 PM

The case is about vodafone tax issue.
Vodafone thought of entering Indian telecom industry in 2007. So they wanted to enter India
by purchasing Hutch company which will be easier for them to enter.
Vodafone purchased CGP investment holdings from Cayman Island of Hutch which included
67% shares of HEL(India).
Though CGP includes shares of HEL the question of paying tax to Indian Government
doesn't arise as Indian IT department had no legal rights to charge tax on overseas
transactions.
For Vodafone
by OMKAR HAWALDAR - Monday, 30 March 2020, 3:55 PM
The case is all about the TDS tax that Vodafone Which is Netherlands company didn't pay and
relates to the entrance of the company in the Indian Telecom market.
Referring to the case
1. Vodafone was charged and penalised for tax evasion which was very wrong step taken by the
income tax department of India.
2. Firstly there was no direct rule mentioned in the year 2008 for paying of taxes by FDI. They
should first ammend their taxation rules and then send notices to such telecom companies like
vodafone.
3. According to me vodafone has not done anything wrong by not paying the tax as the rules were
not imposed properly by the Income Tax department and hence they cannot demand huge
penalties from vodafone who has already paid a huge sum of ₹ 2500 crores obeying the orders of
honorable Supreme Court.
Against Vodafone
by Sharvari Agnihotri - Monday, 30 March 2020, 3:55 PM

Vodafone case study: against the company

1: Vodafone entered Indian markets in 2007,while entering only it was very much cautious
due to strict legal,social,political factors prevailing in the country.
2: It indirectly acquired Vodafone international holdings entite transaction was conducting in

Cayman islands with full proof agenda if avoiding tax in the first place which was against the
policies.
3 : No capital gain tax was paid on the same.The assets involved in the deal were located in
India. It was common practice in international law for foreign investors to invest in India
through foreign holding or operating company to avoid the rules and lengthy approval and
registration process which means from first only it was not following any rules.
4: With no other option left Vodafone decided to challenge Indian judicial system.
According to the law if, a structure is used for circular trading or round tripping or to pay
bribes then such transactions, though having legal form should be discarded applying the test
of fiscal nullity.
5: Governement did not lose hope and tried to bring amendment in the current polices so that
companies like Vodafone should not intentionally avoid taxes for their benefits.
6: Vodafone was making money for the asset in India and was not paying taxes in the Indian
origin which was not accepted by the government very well .
For vodafone
by Deepali Jadhav - Monday, 30 March 2020, 3:51 PM

The case is about Vodafone is entering the indian telecom business. The tax department
demanded a heavy taxes. Vodafone file a case in court and as per the supreme court's
decision Vodafone is not liable to pay the tax because
1. Vodafone didn't purchase the HEL company but they purchased the shares of that
company.
2. There was no "look through" provision in section.
against
by vinay kamat - Monday, 30 March 2020, 3:50 PM

Even though the Vodafone-Hutch deal was offshore, it was taxable as the underlying asset
was in India and so it pointed out that the capital asset; that is the Hutch-Essar or now
Vodafone-Essar joint venture is situated here and was central to the valuation of the offshore
shares; that through the sale of offshore shares, Hutch had sold Vodafone valuable rights - in
that the Indian asset including tag along rights, management rights and the right to do
business in India and that the offshore transaction had resulted in Vodafone having
operational control over that Indian asset. The Department also argued that the withholding
tax liability always existed and the amendment was just a clarification.
For vodafone
by Vishal Nakadi - Monday, 30 March 2020, 3:42 PM

Vodafone Telecom company looking forward to start a business in india purchased an

intermediate company at Caymans Island knows as 'CGP Investment Holding' which holded
67% share of Hutch Essar, India.
This strategy was used by both the companies to avoid tax payment to the Government of
India.
The Government then filed a case against vodafone and won,but lost in Supreme Court after
Vodafone filed for SLP.
The favourable point for vodafone was transfer of share in CGP did not result in transfer of
Capital Asset suitated in india and such gains were not subject to Income Tax then.
There was however amendment to the IT Act to avoid such losses in 2012.
All Vodafone Telecom did at that time was "Unethical" and "Not illegal"
Vodafone case study
by Komal Kalyani - Monday, 30 March 2020, 3:42 PM

As India is a sovereign n democratic country, wch is followed by rules n regulation. It's was
the duty of the president to look after the legal issues taking place by the Vodafone company
in india. As Vodafone was completely depend on the india, so president could mk certain
decision to solve the problems and to help the international company with certain legal n
business rules which have be followed so the president could help the company with as per
laws of india. Each n every country has it own business laws which makes easy to solve the
problems of business and it's imp to know the n get knowledge about legal and business rules
n regulation, to come into contact with each business environment.
For Vodafone
by Mary Kudnavar - Monday, 30 March 2020, 3:40 PM

As we know the business people smartly invest the money. So even Vodafone before entering
the Indian market studied the laws of country and decided what to do.
As in 1998 the Hutch company opened its intemediator CGP investment which had 67% of
shares in HEIL. The Vodafone company buyed it and became 67% shares owner. Now the
case was filed against them as the Vodafone buyed India company it has pay the taxes but
Vodafone said we did nt buy the company so we can't pay the taxes so now complaint was
filed against Vodafone and it lost so it filed . Vodafone filed in supreme court and won the
case because it followed all the rules of the Indian Tax Department. And I'm in favor of
Vodafone.
The case was full about the tax which was not paid but Vodafone followed all the rules of the
country so there is nothing against company
For Vodafone
by Jyoti Bhadaganvi - Monday, 30 March 2020, 3:34 PM

The case study is related to investment in telecom business of Vodafone and tax paying
issues.
In the year 2007 ,Vodafone indirectly acquired through Vodafone international holdings by
Dutch entity and registered with Cayman islands which controlled 67 percent of an Indian
company Hutchinson essar Ltd.
The government of India asked for CGT and TDS because when the foreign company
purchased Indian companies thay need to pay tax ,but the company argued that we not
purchased Hutchinson essar Ltd, we are purchased intermediate company so we need not too
pay legal taxes for this issue and won the case also.
Against the Vodafone
by Numan Shaikh - Monday, 30 March 2020, 3:29 PM

In August 1991, the Government of India constituted a Tax Reform Committee. The
committee recommend that foreign companies have to pay tax at rate of 40% on incomes
other than royalties.
Vodafone has to pay tax for using Indian asset. Hutchison was taxable in India, so Vodafone
is liable to tax.
Vodafone case study
by brundarika Akula - Monday, 30 March 2020, 3:25 PM

The Supreme Court has some reaching principles relating to international taxation. An
important point that the court appears to have highlighted to the Government of India is to
bring about a certainty in tax laws. This decision of the Supreme Court should be appreciated
for the aggression that the I-T department has said that of various tax payers. Whether it is a
multinational as is the case in the Vodafone situation or whether it is a local company or an
individual, the common thread that is to tax.
for Vodafone
by Prajakta Patil - Monday, 30 March 2020, 3:22 PM

we can see that ..Vodafone and hutch that even if the assets involved in the deal were located
in India . there was no need to pay tax to the government of India .
in effect,the supreme court judges have held in favour of VIH and have ruled that sale of one
share if CGP by HTIL to VIH did not give rise capital gains that was chargeable to tax in
India and accordingly, VIH was not liable to deduct tax at source from the payment made by
it to HTIL.
In order to get sucess in different products of vodafone company it implemented various

levels of strategies like it focused on new product development, manufacturing different
products like fixed line solution , data services etc
Against the topic
by Srushti kalburgi - Monday, 30 March 2020, 3:10 PM

When a business considers to start a business or venture or an investment in another country,
it takes a decision reflecting its attitude towards risk whether in favour of the company or
against and its assessment of the prevailing laws on labour, investment , tax or trade. If these
are amended in future and any changes are made the risk model can be redesigned for future
investment this it becomes necessary for vodafone to implement changes regarding the taxes
according to changes made in India. And hence vodafone is liable to pay taxes as the business
was run in India.
For Vodafone
by Prachi Shivangekar - Monday, 30 March 2020, 3:09 PM

The case is all about Vodafone entering the Indian Telecom business . And tax issue .
The tax department of India demaded heavy sum from Vodafone company , but
company refused to pay , so they failed a case , supreme Court of India gave decision in
Vodafone favour because
• Indian revenue authorities had no judrisdiction to tax the foreign transaction
•. Capital assets is not taxable in India so there is no question of asking taX
Against Vodafone
by Vrushabh Bothara - Monday, 30 March 2020, 3:09 PM

Today the ways of tax avoidance have become far more complex. Hence the anti avoidance
provisions are even more complex. This ongoing process of tax planning and anti avoidance
provisions has made tax compliance costly and unbearable.
Vodafone decision by Honourable Supreme court is unfair and hence against the interest of
tax payers and the country as a whole. Can we devise a tax law, administration, tax practice
and tax jurisprudence which is based on striking a reasonable and fair balance, If we can be
fair at every level, India’s future can be better.
Against Vodafone
by Raveena Patil - Monday, 30 March 2020, 3:04 PM

This case basically deals with Vodafone - a British mobile company which had decided to
enter into the Indian Telecom market in 2007
Firstly Vodafone paid about $11 billion for this deal . But did not paid even a single penny as
capital gain tax.and which was against the taxation law of India.
After had feeling of cornered and no option left it wanted to challenge with proper legal
actions.Vodafone filed petition in Bombay High court.As given in the case though the case
might be in favour of Vodafone,but the tax department was correct to it's law and Vodafone
should follow the Indian law.and it's most obvious that the capital gain taxation should be
paid by the Vodafone
Against Vodafone
by Shweta Yadav - Monday, 30 March 2020, 3:03 PM

The tax department demanded its pound of flesh and a show- cause notice was issued to
Vodafone to explain as to why it did not deduct the capital gains tax while making the
payment. It was Vodafone's fault if it did not do that. And for Vodafone's fault why should
government suffer? So the Vodafone was asked to pay to the tax department more than $1-
billion and after adding penalty and interest, the sum was even more than $2.5 billion.
Finding itself cornered and with no option left , Vodafone decided to challenge this order
in a proper judicial forum.
For the case
by Prajakta Jadhav - Monday, 30 March 2020, 3:01 PM

The case is about is Vodafone liable to pay tax in India as British investors had made an entry
in telecom industry to fund vodafone (purchased the shares of the company).
As the foreign investment is concerned they are not liable to pay tax until they start a
business and here they have purchased the shares of the company so they aren't liable to pay
tax.
for vodafone
by vijay ganji - Monday, 30 March 2020, 3:00 PM

> If today you buy 10% of the shares of a particular company, let us say Jet Airways, does
this mean that you automatically own 10% of all of Jet Airways' assets?
Does this mean that 10% of the entire fleet of aircraft now belongs to you? By buying out a
company that holds 67% of HEL, it doesn't mean that Vodafone now owns 67% of the assets
of HEL.
Those assets continue to belong to HEL, which is a separate legal entity based in India. Read
the Company law,
Section: 195(1) As capital asset not taxable in India.
Section: 195(1)
- As capital asset not taxable in India,
- No question Tax Deducted at Source • Us 195(1)
As we see tax department had never asked for CGT to HUTCH before als
Against Vodafone
by Nazim Tahsildar - Monday, 30 March 2020, 2:57 PM

 Does asking a non-resident to comply with Indian legal procedures amount to

ExtraTerritorial Jurisdiction Can a company merely having a incorporation certificate of a tax
heaven country and a few files in its office, should be allowed to evade taxes by various
methods?
 Hutchinson holds 67% market share what was the need to go into the joint venture with
Vodafone did they help Vodafone to safe tax and had their own share of money to be
received by Vodafone for doing this?
Against Vodafone
by Sneha Rajput - Monday, 30 March 2020, 2:57 PM

Vodafone international holdings planned to enter the Indian telecom market during 2007.
They had two option one to build there own infrastructure structure or to buy already setup
company in low price to reduce there work. They thought of buying HEL in ₹ 55000 crore,
but in 1998 the hutch already established intermediate company in Cayman island called
CGP investment holding to get rid of taxes. Whose parent company was situated in
Hongkong called Hutchison telecommunications international Ltd. CGP investment holding
had 67℅ shares of HEL. So to get protected from taxes both the companies made a plan and
according to that plan Vodafone thought of purchasing CGP invested holding instead
company. Buying CGP was like buying the company indirectly which was wrong.
For vodafone
by ABHISHEK PATIL - Monday, 30 March 2020, 2:57 PM

Vodafone lifted up the IT act, studied so well , and done with the purchase process , vodafone
already knows that the CGP Investiment holding company have the 67% of shares of Hutch
company , so acquiring CGP Investiment holding company will make Acquisition of Hutch
company as well , so they done with that process , and also they know that there is no tax
payment stated for shares of Indian company. So they made a talented move ,
For Vadafona
by Soumya Butale - Monday, 30 March 2020, 2:56 PM

Hutch essar ltd was a Indian company and it was acquired by vadafona international holding
BV and as per tax laws in India the vadafona was not liable to pay the taxes but, the tax
authorities demanded for paying tax. The vadafona filed the case against the indian tax
authority at Bombay high court and won the case against the tax authority, as there was no
liability to pay tax by vadafona international holding, as hutch essar ltd was an Indian
company.
For vodafone
by Pranali Padaki - Monday, 30 March 2020, 2:56 PM

The case is about the vodafone a telecom company which is trying to enter into the Indian
telecom business. This case is about the TDS and the TAX which the vodafone denied to pay
to the Indian government. And following is the reason
In the case we can see that the judgement was passed in the favour of Vodafone .
1.Vodafone company was trying to enter the india telcom business. They had two options
either to establish a their own telecom set up with various infrastructure, and branches which
could cast a huge amount and another option was to purchase an existing company.
2. In this case Vodafone thought of purchasing Hutchinson Essar Ltd. Of India .but the came
to know that HEL had already established an intermediate company Cayman Islands which
is an investing holding company.
3.As Vodafone got to know this, they thought that instead of purchasing ths company they
can purchase the share of the HEL.
In this scenario, Vodafone is not liable to pay any TAX to the government as the did not
purchase the HEL company. Insted the purchased the Shares. And the purchase was not
directly from the company. They purchased the Shares through the intermediate.
For vadafone case study
by Asmita Shreyakar - Monday, 30 March 2020, 2:56 PM

Acquisition is purchase of one company by another in which no new company is formed.
1. Vadafone sold 100% holding of CGP to VIH HTIL VIH , CGP HEL vadafone essas ltd
VEL.
2. India revenue authorities opinion CGP was created to take benefits of tax exemption
concept of substance over for transportation was to transfer rights .
3. Vadafone petition to HC and SC insfead of responding to the notice of Indian revenue

authorities VIH Field a write petition to the Bombay high court challenging jurisdiction of
income tax department. The supreme court disposed the case with the direction to tax
authorities to decide the preliminary issue of jurisdiction.
4. Decision by Indian tax authorities was a holding company and was not engaged into any
business in Cayman Island. thus, the situs of shares existed where the underlying assets i.e
India.
5. After going through the agreement and it can be interpreted that the intension of the parties
was ultimately to transfer the controlling interest in HEL which was situated in India and the
tax authorities passed an order under section 201 holding that they had jurisdiction to proceed
against vadafone for failure to deduct tax.
6. Later vadafone write petition to HC and SC and field a write petition to the Bombay high
court challenging the order of income tax authorities and Bombay high court dismissed it.
Again vadafone field a special leave petition in supreme court of India and supreme court
admitted it .
7. The supreme court decision the Indian revenue authorities had no jurisdiction to tax the
foreign transactions , as sale of share was in Cayman Island. Transfer of shares in CGP
doesn't amount to transfer of capital assets situated in India as per section 9 (1) (I).
Against Vodafone
by Hema Guraddi - Monday, 30 March 2020, 2:55 PM

Vodafone should not fight with the government because, the Govt. can change the laws any time
and bring a tough time.
Against
by Soumya Gouranna - Monday, 30 March 2020, 2:46 PM

The case concerns a tax dispute between the Vodafone group and IT authorities. Vodafone
company is responsible to pay the taxes when the assets involved in the deal were located in
India.and The IT department’s argument was based on Section 9 (1) (i) of the ITA that said,
“all income accruing or arising, whether directly or indirectly, through or from any business
source of income in India or through the transfer of a capital asset situate in India." So the
Vodafone company is liable to pay the tax.
For Vodafone
by Shubham Hande - Monday, 30 March 2020, 2:44 PM

1.Case is about Vodafone entering Indian Telecom industry and they made joint venture with
Hutchison essar Ltd company which is indian company .legally when when sells it's property
they have to pay CGT to government.
2. Vodafone had not paid TDS for buying the property to escape from tax Vodafone thought
of buying CGP investment which holds Hutchison essar ltd
3. CGP had shares of 67% HEL Vodafone thought of purchasing shares instead of
company .As TDS has not been paid by Vodafone income tax filled the case against it but
according to laws Vodafone is not laible to pay tax because they didnt directly purchase
company but got through third party.
Against
by Pooja Neelgar - Monday, 30 March 2020, 2:42 PM

This recent case deals with transfer of shares of an Indian Company held by a foreign
company to another foreign company. Transfer of Capital Assets in India and Chargeability
of transaction to tax under Income Tax Act Section 9 (1) of Income Tax Act, 1961.What is
even more astonishing is that the quantum of money involved in the dispute was something
that they could have easily handled on an ongoing basis, year after year. Even if they wanted
to fight the case in the court it was always open for them to pay the disputed levies ‘under
protest’ and recovered it back from the government, with even interest, once the court decides
in their favour.
For vodafone
by Twinkle Kavediya - Monday, 30 March 2020, 2:39 PM

Referring to the case of vodafone where they were charged and penalised for tax evasion is
very wrong step taken by the income tax department of India.. Firstly there was no direct rule
mentioned in the year 2008 for paying of taxes by FDI..They should first ammend their
taxation rules and then send notices to such telecom companies like vodafone.. According to
me vodafone has not done anything wrong by not paying the tax as the rules were not
imposed properly by the IT department and hence they cannot demand huge penalties as
vodafone has already paid a huge sum of RS 2500 crores in the past following the orders of
supreme court.
For Vadafone
by Shreya Sainuche - Monday, 30 March 2020, 2:36 PM

Vadafone is a British mobile company.they have started in india by year 2007.After

launching tele service in India they have purchased Hutch by $11billion.they have many
opportunities to get the market aslo the price of the product is reasonable.
Vodafone case study (against)
by Anushree Navelkar - Monday, 30 March 2020, 2:35 PM

Vodafone can aquire another company is hutch India by purchasing share of partially holding
company (CGP) of that other company through an agreement with the 100% holding
company of CGP is HTIL without attracting tax on capital gain in India.
Vodafone was embroiled in a $2.5 billion tax dispute over it's purchase of Hutch India in
April 2007. The transaction involved purchase of assets of an Indian company, and therefore
the transaction was liable to be taxed in India as per the allegations of tax department.
Vodafone group entered in India through a subsidiary based in Netherlands which acquired
HTIL's stale in HEL the joint venture that held and operated telecom licenses in India. This
agreement gave Vodafone control over 67% of HEL and extinguished Hong Kong based
Hutchison's right of control in India,a deal that costs worlds larget telco $11.2 billion at the
time.
The Crux of dispute had been whether or not the Indian income tax department has
jurisdiction over the transaction.
In January the supreme Court passed the judgement in favour of Vodafone saying that Indian
income tax department that no jurisdiction to levy tax on overseas transactions between the
companies outside India.
Government changed its income tax act retrospectively and made sure any company,in
similar circumstances is not able to avoid tax by operating out of tax-havens (Cayman islands
and Lichtenstein). In may 2012, Indian authorities confirmed that they are going to charge
Vodafone about $4.5 billion in tax and fines.
For Vodafone
by Ganesh Dundi - Monday, 30 March 2020, 2:33 PM

Because of an this incident the Income Tax revised and updated its act after this incident for prevent
the future happenings of this type of cases, so this will help the Government to be cautious in the
future.
And also Vodafone played Business geme in it for avoiding tax payment , because of IT Dept
had a loop in its Tax payment act , there is nothing as mentioned where owner company or
Purchasing company have to pay tax for selling company purchased shares of Indian
company. So Because of this Loop in the IT act Vodafone gained the benefit.
Against Vodafone
by Sanket Sunthankar - Monday, 30 March 2020, 2:31 PM

After the verdict of supreme court,tax laws were amended with retrospective effect and
demands were raised again. Vodafone disputed this levy and the matter is before an
International arbitration panel. This is an ongoing litigation on account of withholding tax
obligation of a payer (Vodafone) which matter is under arbitration in the UK. The result of
the arbitration will decide whether Vodafone has any withholding tax liability in India or not,
till then the verdict of Supreme court doesn't hold good.Still the matter is in International
Arbitration Panel
Against Vodafone
by Kirti Mehta - Monday, 30 March 2020, 2:31 PM

Vodafone tried to enter the Indian telecom market indirectly with the help of Hutchison group and
Vodafone paid 11 billion dollars for the deal. And not even a single penny was paid by either of the
parties as capital gains tax which was not liked by the government of India. Later when the Bombay
high court stated that Vodafone was liable to pay certain amount, it challenged to the supreme
Court of India where the favour was for Vodafone. This made the government of India embarrassed
and where not convinced by the verdict. Also, when P. Chidambaram and Mr. Pranab Mukherjee
came to light, they were for the fact and same opinion that " it is not that someone will make money
on an asset in India and not pay any tax in India. India is not inferior to anyone. We cannot ne a tax
haven just to attract foreign investment."
Though the Verdict was in favour of Vodafone, the dispute is still on the same that Vodafone
has to pay the amount or the tax for using the assets of India.
Against
by Divyajyoti Naik - Monday, 30 March 2020, 2:24 PM

Vodafone took place of hutch Essar in india the government then ask them about tax.
Vodafone which itself is operating from an intermediary company in Netherlands stand their
hands out by saying that we didn't purchased CGP investment holding to cayman island now
what we do if there are 67% shares of hutch Essar india in it ,we are not liable to pay your
tax. Indian government is left with no other option than to file a case against vodafone india
at high court which it won but it lost that case in supreme court .
For Vodafone
by Ninad Patil - Monday, 30 March 2020, 2:24 PM

1. When you start a new business it is obvious to charge tax. As we earn income by running
business in that country, but it is wrong to charge high amount of tax. So I think government
authority is wrong in this particular decision.
2. They need not pay tax as they didn't purchased the company but they purchased the Share
of others company so they aren't liable to pay tax.
For Vodafone
by sonam malji - Monday, 30 March 2020, 2:24 PM

Vodafone Head I Win, Tails You Lose
The Indian Supreme Court's decision in the Vodafone case brings to an end the long saga that
has kept global investors on edge about the taxation of foreign acquisitions in India. Against
settled principles of the taxation of cross-border acquisitions, the Indian tax authorities has
taken a highly aggressive position that has subjected a sale of stock of a non-Indian
corporation by and between two non-Indian residents to Indian taxation. Vodafone's win
sends a positive signal about India's legal climate to global investors. However, the Indian
government is considering new laws that may undo some of this decision's clarity.
Decision of the court:

On January, 2012, the Indian Supreme Court ruled in favor of Vodafone. It holds that the
transaction between HTIL and Vodafone is a bona fide structured foreign investment into
India and fell outside the scope of India's territorial tax jurisdiction. The Supreme Court has
also observed the principle that a taxpayer can legitimately arrange it's affairs to minimize It's
taxes so long as it does not violate particular laws or legislation. The Supreme Court has
underscored the distinctions between "tax planning" and improper "tax avoidance" and holds
that the Vodafone transaction is a planned investment not undertaken for improper tax
avoidance purposes. The Supreme Court has stated that the following facts and circumstances
must be used in order to determine whether a transaction can be considered to be improper
tax avoidance or tax planning. They are :
 extent of participation in investment by the foreign entities;

 duration of time that the holding structure existed;
 period of business operations in India; and
 generation of taxable revenue in India during the period of business operations in
India; timing of exit.
The Vodafone judgment however reiterates the benefits of tax planning in cross-border
acquisitions involving India and provides comfort to global investors that Indian courts will
uphold the rule of law.
Against
by Mitali Nevagi - Monday, 30 March 2020, 2:23 PM

Vodafone would have been faithful in paying tax to India instead of searching different ways
to save the tax.
For vodafone
by Rutuja Patil - Monday, 30 March 2020, 2:14 PM

We can see that.... Vodafone and hutch that even if the assets involved in the deal were
located in India.there was no need to pay tax to the government of India..
As supreme court judgement says that there was no where mentioned in the section that there
was "look through "provision mentioned in the section....
So I admire and agree that Supreme Court judgement was in favor of Vodafone and there
was no need to pay tax to govt of India
For Vodafone
by Vishal Kurade - Monday, 30 March 2020, 2:13 PM

As per the supreme courts decision ,which says Vodafone is not liable to pay tax .court
states that ,
1)The indian revenue authorities had no jurisdiction to tax the foreign transactions, as of
shares was in Cayman island.
2) As capital asset is not taxable in india ,so there is no question of deducting the tax at
source under section 195(1).
Its clearly seen that supereme court reversed the decision of bombay high court.
For
by Keerti Karmuse - Monday, 30 March 2020, 2:06 PM

demanded a heavy sum to be paid. Vodafone denied the liability. The dispute was
For Vodafone
by Mumtaz Naik - Monday, 30 March 2020, 2:01 PM

The case relates to Vodafone entering the Indian telecom business. The case is all about the
TDS tax that Vodafone Which is Netherlands company didn't pay. The Reasons are:
Firstly Vodafone company thought of purchasing the Hutchison Essar Limited of India in
55000 crores. But then they got to know that Hutch company had already established a
intermediate company in Cayman Islands named CGP investment holding and it's parent
company was in Hong Kong named Hutchison telecommunications international limited
(HTlL).
CGP investment holding had already 67% shares of Hutchison Essar Limited so Vodafone
thought of purchasing these shares of HEL instead of purchasing the company.
Here legally they don't need to pay the tax at that time because they didn't directly purchase
the company but through another intermediate company they purchased the shares of the
company so it was not legal to pay the tax.
Against Vodafone
by Priyanka Mahindrakar - Monday, 30 March 2020, 1:58 PM

Vodafone found a easy way out to enter the Indian Market by indirectly acquiring the
complete share capital in CGP-A company in Cayman island which controlled 76% of Indian
Company
Vodafone made a deal of $11 billion with Hutchison Group Ltd ( A joint Venture between
Essar group from India and Hutchison Group from Hong Kong
The first fault of Vodafone was it did not deduct the capital gains tax while making payment.
According to the Indian law if a foreign company starts its operation in India with the assets
in India then the company is liable to pay relevant taxes. But vodafone failed to do so
Vodafone clearly made use of the loopholes that were then present in the law to circumvent
the legal framework of tax department to avoid paying taxes. Vodafone used Transaction of
Tax avoidance and Transaction for Investment.
Any income accruing or arising in India directly or indirectly from its business connection in
India or through, or from any property in India or from any asset in India, such Income is
taxable.
with vodafone
by Akash Patil - Monday, 30 March 2020, 1:54 PM

As we can see that Supreme Court of india gave the judgement in favour of Vodafone.
And i support their judgement that there was no need for vodafone to pay the tax as we can see that
their was no ''look through '' provision in the section and hence ,this particular section cannot be
used to tax in direct transfer of the assets situated in india .
lets see what ''look through'' provision say
-section 9 of the ''income tax act 1961'' provided for ' look through' and what mean 'in consequence
of' as follows
''section 9(1) The following incomes shall be deemed to accrue or arise in India;
-all income accruing or arising.weather directly or indirectly,through or from any other business
connection in India,or through pr from any property in India,or through or from any assetr or source
of income in India ,or through the transfer of a capital asset situate in India.
Agnist
by Pooja Halkarni - Monday, 30 March 2020, 1:47 PM

THE BOTTOM LINE OF CASE
According to Indian law a foreign company is liable to pay 20.56% of tax if they are earning
above 10cr n Vodafone net worth is around 142.56 euro so technically they are liable to pay
tax which they did not so hence they are at fault
For
by Nikhila Rattu - Monday, 30 March 2020, 1:46 PM

1) In order to get sucess in different products of vodafone company it implemented various

levels of strategies like it focused on new product development, manufacturing different
products like fixed line solution , data services etc
2) it's effective diversification strategy has helped to provide it's products and services to its
customers in more effective way all over the world like europe, middle east, US and
emerging markets such as Africa
Against
by Vishal Kagati - Monday, 30 March 2020, 1:45 PM

Vodafone entered the huge Indian telecom markets by working out a ownership transfer deal
in one of the shady islands where most tax evasion deals are made. Only in this case the size
of the lolly was too big for the Govt to ignore, something like 55000 crores. The tax
department demanded a heavy sum to be paid. Vodafone denied the liability. The dispute was
Against the topic
by Mansi Patil - Monday, 30 March 2020, 1:43 PM

demanded a heavy sum to be paid. Vodafone denied the liability. The dispute was finally
decided by the Supreme Court of India in Vodafone’s favour. Even if the case was given in
favor of Vodafone, the tax department was right as the business is carried out in India, they
earn a money so it is obvious to pay tax by Vodafone.
Agnist the topic
by Pooja Halkarni - Monday, 30 March 2020, 1:18 PM

This first wrong descion by Vodafone -
1. Vodafone made a deal with hutchson group n they paid 11 billions for this so it's. first
fault it did not deduct capital gains tax while making this deal
2. Hutchinson holds 67% market share what was the need to go into the joint
Venture with Vodafone did they help Vodafone to safe tax and had their own share
of money to be received by Vodafone for doing this?
3.vodafone sold it's stake in China for 6.65 billion out of frustration that means they. are
capable of doing anything to safe money even if that means invading one's countrys law n
saving tax money .
Against Vodafone
by Zaki Khan - Monday, 30 March 2020, 12:57 PM

Whenever a foreign company derives its share value form an Indian company it is liable to
pay tax, hence Vodafone were liable to pay tax to the Indian government.

Against Vodafone: Anusha Patil

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Against vodafone

by Anusha Patil - Monday, 30 March 2020, 5:59 PM

by Ashwini Ramesh - Monday, 30 March 2020, 5:56 PM

by Hayawadan Ayachit - Monday, 30 March 2020, 5:55 PM

Therefore, Vodafone was completely fair in it's practice according to me.

by Kiran Dhamune - Monday, 30 March 2020, 5:55 PM

by Karan Mane - Monday, 30 March 2020, 5:55 PM

by Apurva Rajput - Monday, 30 March 2020, 5:54 PM

by Simran Sayed - Monday, 30 March 2020, 5:54 PM

by Naveen Naveen - Monday, 30 March 2020, 5:53 PM

1.It has no presence in India at the time of transfer of share.

8.There was however amended to the IT Act to avoid such losses.

by Tushar Bharamgonda - Monday, 30 March 2020, 5:50 PM

Cayman Company–CGP Investments (Holdings) Ltd from a foreign company Hutchinson

-all income accruing or arising.weather directly or indirectly,through or from any other

by Saniya Quadri - Monday, 30 March 2020, 5:47 PM

by Anup Yankati - Monday, 30 March 2020, 5:47 PM

-all income accruing or arising.weather directly or indirectly,through or from any other

by Shreya Kapase - Monday, 30 March 2020, 5:45 PM

Transaction amounting to transfer of capital assets in India, by divestment of controlling

by Dhanashree Chougule - Monday, 30 March 2020, 5:43 PM

Government has no jurisdiction over vodafone's purchase of mobile assets in India.

by Pakshal Mehta - Monday, 30 March 2020, 5:42 PM

by saniya bhaldar - Monday, 30 March 2020, 5:39 PM

In this case two issues are involved :

i. Taxability of the transaction. Paragraphs II.1 to II.18

ii. Vodafone’s liability to deduct tax at source. Paragraph II.19

We are personally against Retrospective Amendments. Normally, a retrospective amendment

by Omkar Dongre - Monday, 30 March 2020, 5:38 PM

by Nagaratna Marihal - Monday, 30 March 2020, 5:38 PM

by saniya bhaldar - Monday, 30 March 2020, 5:36 PM

In this case two issues are involved :

i. Taxability of the transaction. Paragraphs II.1 to II.18

ii. Vodafone’s liability to deduct tax at source. Paragraph II.19

We are personally against Retrospective Amendments. Normally, a retrospective amendment

by Akshata Bagadi - Monday, 30 March 2020, 5:33 PM

2. Vodafone's network failure is suspected to be because of BBMP's drive to remove optical

3. '#Vodafonedown' is trending on Twitter today. The telco's network is reportedly down in

by Shriya Chiniwalar - Monday, 30 March 2020, 5:33 PM

by Nikhil Rao - Monday, 30 March 2020, 5:33 PM

by Manjunath Bhat - Monday, 30 March 2020, 5:31 PM

Vodafone case study

by Samantha Dharamdasani - Monday, 30 March 2020, 5:28 PM

by Rahul Patil - Monday, 30 March 2020, 5:23 PM

Cayman Company–CGP Investments (Holdings) Ltd from a foreign company Hutchinson

Vodafone case study

by Aishwarya Kolkar - Monday, 30 March 2020, 5:23 PM

•. Capital assets is not taxable in India so there is no question of asking taX

Against Vodafone Against the topic

by Padmanabh Bhat - Monday, 30 March 2020, 4:52 PM

For the topic

by sneha malkari - Monday, 30 March 2020, 4:52 PM

by Sarvesh Majati - Monday, 30 March 2020, 4:49 PM

by Divya Palankar - Monday, 30 March 2020, 4:47 PM

5. The tax does not necessarily lead to assumptions of evasion of taxes

by Mitali Nevagi - Monday, 30 March 2020, 4:43 PM

by gurunath Shiroorkar - Monday, 30 March 2020, 4:41 PM

by Pearl Colaco - Monday, 30 March 2020, 4:39 PM

by Vishwanath Kengnal - Monday, 30 March 2020, 4:37 PM

Vadafone case study

by Raghotam Chimmalagi - Monday, 30 March 2020, 4:36 PM

by Vijaylaxmi Deyannavar - Monday, 30 March 2020, 4:35 PM

In 2007, Vodafone indirectly acquired through Vodafone International Holdings BV –