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I-T drops ₹8,500-crore transfer pricing case against Vodafone Group
The Economic Times· 2025-11-03 18:32
Core Viewpoint - The Income-Tax Department has withdrawn a long-standing ₹8,500 crore transfer pricing case against Vodafone India Services, following a Supreme Court ruling that allows the government to create a special package for Vodafone's adjusted gross revenue (AGR) liabilities exceeding ₹83,400 crore [1][6]. Group 1: Case Background - The case involves a transfer pricing order related to the sale of Vodafone India's Ahmedabad-based call center business to Hutchison Whampoa Properties India during fiscal year 2007-2008 [1][6]. - Vodafone India Services had previously challenged the jurisdiction of the tax department, which sought to add ₹8,500 crore to its taxable income for the fiscal year 2007-2008 [2][6]. - The Income-Tax Department had claimed ₹3,700 crore in taxes from Vodafone India in this context back in 2013 [2][6]. Group 2: Legal Proceedings - The Income-Tax Department appealed against a Bombay High Court judgment from October 2015 that favored Vodafone India Services, which had overruled an earlier order from the Income Tax Appellate Tribunal (ITAT) [2][6]. - The High Court's ruling indicated that the tax department did not have jurisdiction over the transfer pricing tax case involving the sale of Vodafone's call center business [6]. Group 3: Financial Implications - The withdrawal of the case comes after the Supreme Court's decision, which allows the government to address Vodafone's AGR liabilities, including interest and penalties, totaling more than ₹83,400 crore [1][6]. - The appeal filed by the Income-Tax Department argued that the 'call option' and 'put option' in the transaction were interconnected and should be treated as a 'Forward Contract' [5][6].