Tax signals from Vodafone

The Supreme Court's verdict exempting Vodafone International Holdings (VIH) from any tax liability on its 2007 acquisition of Hutchison Essar's telecom business in India, through a complex maze of inter-connected overseas entities, has many positive takeaways. The ruling reiterates a well-settled principle that there can be no room for intendments in tax law and that the ‘letter' is what counts. If the law doesn't explicitly provide for something, there can be no invoking of ‘substance over form' arguments because it is advantageous to the revenue authorities.

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