Landmark case · Law of Taxation · Semester 6
Vodafone International Holdings BV v. Union of India
(2012) 6 SCC 613 · Supreme Court of India
Look-through taxation of an offshore share transfer was rejected absent a clear charging provision.
From topic
Tax planning, treaty shopping and GAAR — Unit IV, Law of Taxation.
Related sections:
- Income-tax Act, 1961, 90 — Agreement with foreign countries (DTAA)
- Income-tax Act, 1961, 95–102 — General anti-avoidance rule
- Income-tax Act, 1961, 195 — Withholding on payments to non-residents