..., 2012 but with retrospective effect from 1.4.1962. He submitted that in view of this amendment, the decision of the Supreme Court in the case of Vodafone International Holdings B.V. v. Union of...in case of Vodafone International Holdings B.V. v. Union of India [2010] 193 Taxman 100/329 ITR 126 was holding the field and the decision of the Supreme Court in the...case of Vodafone International Holdings B.V. (supra) was not yet rendered. The petitioner, therefore cannot take shelter of the contention that the Revenue is expecting the petitioner to discharge an...

...violation of any statutory provisions. (v) Vodafone International Holdings B.V. v. Union of India...affected simply by virtue of the scheme of amalgamation.48. In the case of Vodafone International Holdings B.V. v. Union of.... The aforesaid matter concerned a tax dispute involving the Vodafone group with the Indian tax authorities in relation to the acquisition by Vodafone International Holdings B.V. (VIH), a company...

...the day of incurring of expenditure itself and accordingly income accrued on that date. Learned DR relied on the decision of Bombay High Court in the case of Vodafone International Holdings B.V...favour of the assessee by the Tribunal order cited supra. The decision relied on by the learned DR in the case of Vodafone International Holdings B.V (supra) does not apply to the present case as the...

...gathered from the document by reading the same as a whole.27. In Vodafone International Holdings BV v. Union of India (2012...order to determine its real purport.26. In Delta International Ltd. v. Shyam Sundar Ganeriwalla (1999) 4 SCC 545, AIR...

...resolved in favour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner (supra) as followed by judgments of this Court - See Vodafone International Holdings BV v. Union of India...language is used, if it alters or changes the law as it earlier stood. This was stated in Sedco Forex International Drill. Inc. v. CIT, (2005) 12 SCC...

...more recently in the case of Vodafone International Holdings B.V v. Union of India, [2012] 170 Comp Cas 369 (SC...Vodafone International Holdings B.V, [2012] 170 Comp Cas 369 (SC); [2012] 341 HR 1. The Supreme Court also considered the interpretation..., [2003] 263 HR 706; [2003] 1 RC 742; (2004) 10 SCC 1 and Vodafone International Holdings B.V...

.... Guzdar v. CIT AIR 1955 SC 74, (1955) 1 SCR 876 and Vodafone International Holdings BV v. Union of India...

...India.31. The learned Senior Counsel submitted that assigning of a PI is a well-defined concept and, referring to the judgment of this Court in Vodafone International Holdings BV...subsidiary, Cairn UK Holdings Limited. Upon its acquisition of 50%, Shell's interest under the contract, CEIL became the operator under the operating agreement with effect from 1-1-2000...subsidiary, Cairn UK Holdings Limited. Upon acquisition of 50% of the Shell's interest under the contract CEIL became the operator under the operating agreement w.e.f 1-1-2000. Cairn later announced on 16...

...Vodafone International Holdings B.V… v. Union Of India & Anr.…, [2009] 311 ITR 46 (Bom) has held that the question regarding taxability cannot be determined on the basis of affidavits...was filed before the hon'ble Supreme Court and the hon'ble Supreme Court by order dated January 23, 2009, in Vodafone International Holdings B.V...court if it is aggrieved by the finding on the jurisdictional fact as observed by the hon'ble Supreme Court in Vodafone International Holdings B.V's case, [2009] 221 CTR (SC) 617. We...

...….”26. In Vodafone International Holdings BV v. Union of India (2012) 6 SCC 613 this Court observed that...considered.15. The Court also considered Ramana Dayaram Shetty v. International Airport Authority of India (1979) 3 SCC...

...Section 201 of the Act is bad in law. Accordingly, learned Counsel tried to rely upon the judgment of the Apex Court in the case of Vodafone International Holdings B v. v. Union of Idia and...i.e., 51% shares of M/s Sesa Goa Ltd. Accordingly, learned Counsel for the Revenue relied upon the decision in the case of Vodafone International Holdings B v. v. Union of India and...Huluvadi G. Ramesh, J. 1. Petitioner is a company incorporated under the laws of Cyprus, It holds 60% of the shares in Finsider International Company Ltd registered in UK...

...SCC 1 (Vedanta case), Balco Employees' Union v. Union of India (2002) 2 SCC 333 (Balco case) and Vodafone International Holdings BV v. Union of...to be different from the apparent transactions. In fact, the principle of law laid down in Vodafone case (2012) 6 SCC 613 that the court can...public.31. In Vodafone case (2012) 6 SCC 613 the dispute arose out of claim by the Income Tax Department to tax...

...Vodafone International Holdings B.V. vs. Union of India & another (2012) 341 ITR 1 (S.C.) relevant page 13 of Supreme Court. It was also submitted that dividend income...., (1973) 88 ITR 192 (S.C.). We further noted that in case of Vodafone International Holdings B.V. (supra) the Hon'ble Supreme Court has observed at page 13, para (v) of its order that...a commercial concept and tax is levied on the transaction, not on its effect. Controlling interst, which stood transferred to Vodafone from HTL accompanied the CGP share and cannot be dissected so as...

...ITR 498/[2009] 183 Taxman 159 (Bom.) and also on the decision of Hon'ble Supreme Court in the case of Vodafone International Holdings B.V. v. Union of India [2012] 341...., [1973] 88 ITR 192 (SC) . We further noted that in case of Vodafone International Holdings B.V. (supra) the Hon'ble Supreme Court has observed at...controlling interest, which is purely a commercial concept and tax is levied on the transaction, not on its effect. Controlling interest, which stood transferred to Vodafone from HTL accompanied the CGP...

...the judgment of the Apex Court in Vodafone International Holdings B.V vs UOI & Anr [2012] 341 ITR 1, the ld. Representative for the assessee submitted that referring...observed by the Apex Court in Vodafone International Holdings B.V (supra), the treatment of a particular item in different manner in the 1961 Act and Direct Tax Code, 2010...refund u/s TUF is capital in nature when the object of subsidy is to sustain competitiveness in the domestic as well as international market. 5. Placing reliance on the judgment of...

...the judgment of the Apex Court in Vodafone International Holdings B.V vs UOI & Anr [2012] 341 ITR 1, the ld. Representative for the assessee submitted that referring...observed by the Apex Court in Vodafone International Holdings B.V (supra), the treatment of a particular item in different manner in the 1961 Act and Direct Tax Code, 2010...refund u/s TUF is capital in nature when the object of subsidy is to sustain competitiveness in the domestic as well as international market. 5. Placing reliance on the judgment of...

...the judgment of the Apex Court in Vodafone International Holdings B.V vs UOI & Anr [2012] 341 ITR 1, the ld. Representative for the assessee submitted that referring...observed by the Apex Court in Vodafone International Holdings B.V (supra), the treatment of a particular item in different manner in the 1961 Act and Direct Tax Code, 2010...refund u/s TUF is capital in nature when the object of subsidy is to sustain competitiveness in the domestic as well as international market. 5. Placing reliance on the judgment of...

...of Vodafone International Holdings B.V Vs. UOI (341 ITR 1)?" 3. According to the...International Holdings B V. V/s. Union of India and Another [2012] 341 ITR 1dealing with chargeability of income covered under this appeal after the Vodafone (supra...Vodafone International Holdings B.V. V/s. Union of India and Another (supra).In absence of explicit insertion of Explanation 4 and...

.... Ltd. (hereinafter referred as "GSPL") and Vodafone International Holdings BV ("VIHBV") as confirming party. The said Agreement provided that as and when permitted by applicable law including the...relied upon the decision of Hon"ble Supreme Court in the case of Vodafone International Holdings vs. Union of India and...Authority found that „AS" did not have the shares of Vodafone International Holdings BY (hereinafter referred as VIH) initially. It also declined an offer of investment in Telecom Investment India...