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This Vodafone MNP ad ,Everybody's Welcome to Vodafone ...clever ad and the music was good..

Between Gwalior and Agra cantt. it briefly passes through Rajasthan and so you got the Vodafone message.

Vodafone International Holdings vs Union of India. This ruling was awaited with bated breath and received with jubilation by taxpayers. I personally witnessed one of the hearings in the Supreme Court, and needless to say, it was one of my most memorable experiences.Vodafone (Netherlands) signed a Share Purchase Agreement with Hutchison (Hong Kong) for the transfer of a 'single' share of Hutchison's Cayman Island subsidiary. This subsidiary, through a complicated stream of downstream holdings woven through Mauritius and India, owned a 67% (52% direct + 15% indirect) controlling stake in Hutchison Essar Ltd in India. With the transfer of the Cayman Island company, the entire business of HEL in India got transferred to Vodafone.Vodafone argued that since the transfer of the Cayman company's share happened outside India, it should not be liable to pay capital gains tax here, since only transfer of capital assets situated in India would attract tax as per Section 9 of the Income Tax Act. The IT Department claimed that the 'substance' of the transaction was transfer of an Indian capital asset i.e. controlling stake in HEL, and hence, the 'form' ought to be ignored and the transaction ought to be taxed.The transaction was worth $ 11 billion and the tax liability was $ 2 bn, not including penalty and interest.Though the transaction would ordinarily be taxed in the hands of Hutch (being the seller), the Department went after Vodafone saying that they should have deducted tax and paid it to the Indian Government at the time of making the payment.The Bombay High Court ruled in favour of the Department, but the Supreme Court ruled unequivocally in Vodafone's favour. SC held that Section 9 does not cover 'indirect transfers' of assets in India in its present form, and if the Government wants to tax that, it should enact suitable legislation. The transaction had a legitimate commercial purpose, justifying its form, and hence, the form was to be respected. The commercial substance involved acquiring of call and put options owned by another Hutchison subsidiary (3 Global Services) which ensured transfer of both the direct and indirect shares to Vodafone. Any other route would not have transferred the indirect shareholding.SC reaffirmed the fine line between tax avoidance and tax planning, extensively discussing important principles laid down by the UK Courts in the cases of Westminster and Ramsay. These principles have been interpreted by Courts in various rulings, while adjudicating on tax planning.What is especially welcome about this judgment is its encouragement for FDI and call for stability.Most outrageously, the Government enacted retrospective amendments through Budget 2012 to UNDO this ruling. They caused such an uproar, that the Government then instituted a Committee to review them. It remains to be seen whether Vodafone is up for a Round 2 at the Supreme Court.Anybody looking to read more about the developments can click here - Faciendum