Vodafone International Holdings B.V vs Union Of India & Anr

The Supreme Court addressed a tax dispute involving Vodafone International Holdings BV and the Indian Tax Authorities regarding the taxation of capital gains from the acquisition of CGP Investments Holdings Ltd. The Court held that the Revenue's claim to tax the capital gains was not valid as CGP, although holding underlying Indian assets, was not a tax resident in India. The judgment clarified the applicability of tax laws in cross-border transactions, emphasizing the need for clear residency status under the Income Tax Act, 1961, particularly Sections 9 and 2(14).