Skip to content
LexBrief
← Back to blog

Vodafone International Holdings v. Union of India

Offshore share transfer; indirect transfer; retrospective amendment debate.

IRAC Analysis

Whether capital gains on an offshore share sale with an Indian underlying asset were taxable in India.

The Court held that Vodafone’s offshore transaction transferring control of an Indian telecom asset was not taxable in India under the law as it stood. The judgment shaped indirect-transfer rules and later legislative amendments.