The disputed issue in the instant case of ‘Vodafone’ related to tax implication on the sale of its call centre business to Hutchison’s India entity and assignment of call option to Vodafone International BV in 2007-08. The Tribunal in case ofVodafone India Services (P.) Ltd. v. ACIT  52 taxmann.com 241 (Mumbai – Trib.) had held that the transaction of sale of call centre business was structured with the motive to “circumvent” the transfer pricing provisions and the transaction was in essence an international transaction between two related parties and, thus, would be subject to the transfer pricing provisions. On the issue related to assignment of call option it held that assignment of call option would fall in the ambit of term ‘transfer’. Thus, Tribunal held against the ‘Vodafone’.
Now the Bombay High Court has ruled in favour of Vodafone and quashes the demand of around 3700 crores.