TRANSACTION
- MAY, 2007: Vodafone acquired stake in Hutchison Essar for $11.2 bn.
- Vodafone International Holdings BV bought the stake of Hutchison Telecommunications International Ltd in Hutchison Essar
- Deal between companies based overseas; executed in Cayman Islands
- TAX TROUBLE
- OCT 30, 2009: Income tax dept served notice to Vodafone International Holdings
- Notice under Sections 201 and 201 (1A) of the Income Tax Act for non-deduction of tax at source on the $11.2 bn transaction
- OCT 30, 2010: IT Dept ordered Vodafone to furnish Rs 11,218 cr under Sections 201 and 201(1A).
- APR 29, 2011: Rs 7,900 cr penalty was imposed
LITIGATION- SEPT 8, 2010: The
- Bombay High Court upheld the tax authorities decision. Dept raised tax demand in the subsequent month
- JAN 20, 2012: SC set aside Bombay High Court decision; quashed tax & interest demand
- It said transaction was between two overseas entities & Indian tax authorities had no territorial tax jurisdiction
- FEB 17, 2012: Govt filed review petition
- MAR 20, 2012: SC dismissed the review petition
- THE RETRO AMENDMENT
- 2012 Indian govt amended the Income Tax Act retrospectively
- Section 119 of the Finance Act validated the tax levied on Vodafone
- Government said the amendment was only a clarification to remove ambiguity and provide certainty
- TAX DEMAND BACK ON TABLE
- JAN 3, 2013: IT dept raised a fresh demand was issued for Rs 11,218 cr
- Vodafone subsequently sought to settle the case
- A committee set up to resolve the issue failed to make any headway
ARBITRATION- APR 2014: Vodafone served arbitration notices under the India-Netherlands treaty
- New government did not roll back demand but said no fresh action under
- retrospective tax
- A fresh demand was issued on February 12, 2016, for Rs 22,100 cr tax
- SEPT 25, 2020: The Hague-based arbitration court ruled in favour of Vodafone
- DEC 21, 2020: India challenges arbitration award at Singapore
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