Supreme Court · 2012 INSC 45 · Decided 20 January 2012
Vodafone International Holdings B.V. v. Union of India & ANR.
- Court
- Supreme Court of India
- Citation
- 2012 INSC 45 · [2012] 1 S.C.R. 573
- Case number
- CIVIL APPEAL No. 733/2012
- Decided
- 20 January 2012
- Bench
- S.H. KAPADIA, K.S. RADHAKRISHNAN, SWATANTER KUMAR (3-judge bench)
- Outcome
- Appeal(s) allowed
- Case type
- Civil
- Acts & sections cited
- Income Tax Act Section 45
Headnote
Income Tax Act, 1961: s.45 read with ss. 195, 201 and 201(1A) - Capital gains B c - Offshore transaction - Territorial tax jurisdiction of Indian tax authorities - Transaction between VIH and HTIL (both companies incorporated outside India) with regard to sale and purchase share capital of CGP, also a D company incorporated outside India - Revenue seeking to tax the capital gains arising from the sale of share capital of CGP on the basis that CGP held the underlying Indian assets - Held: Indian tax authorities had no territorial jurisdiction to tax the said offshore
Judgments are the courts' own published copies, provided for study; they are not certified copies. Source: Indian Supreme Court & High Court Judgments, Dattam Labs (CC-BY-4.0)