Bombay HC Googly - 'A+B' theory

Arguments of Vodafone [Based on the editorial feed provided by BMR Advisors]
Court questions Salve on Mauritius companies
Mr Salve concluded his arguments on applicability of Section 195 of the Income-tax Act, 1961 (‘the Act’) and thereafter reviewed the order of the Department. Mr. Singhvi then presented his...
Section 195 not applicable to Vodafone; argues Salve
In the first hour, Mr Salve addressed question raised by Justice DY Chandrachud in relation to the requirement for obtaining approval from the Foreign Investment Promotion Board of India (‘FIPB&...
Sale of capital asset cannot be brought to tax based on ‘economic nexus’
Mr. Harish Salve continued his arguments on non-taxability of sale of share of the Cayman Island company and his key arguments were ...

Arguments of Income Tax Dept [Based on the editorial feed provided by BMR Advisors]
ASG & Salve argue on nexus of transaction with India on last day of the hearing
Mr Mohan Parasaran elaborated on the legal and tax aspects of his written submissions and thereafter, Mr Salve responded to the arguments of Mr Parasaran....
CGP Share merely a mode; different mode chosen cannot change the situs and nature of the asset, argues ASG
Mr Parasaran discussed the shareholding structure of CGP stating that CGP directly held 42.34% in HEL. Further, CGP held directly 37.25% in Telecom Investments India (P) Ltd (‘TII’), an In...
Vodafone acquired bundle of right and not mere one share of CGP, argues ASG
Mr Parasaran, the Revenue Departments Counsel presented his arguments in response to Mr Harish Salve’s submissions over the past few days. He started by asserting that after hearing Mr Salve&rsq...

Detailed summary of Bombay HC ruling
Vodafone International Holdings BV v. UOI
Hutch transferred to Vodafone controlling interest in HEL along with valuable rights and entitlements; Transfer not a mere transfer of CGP share: Bombay HC  ...