Which sections of the Income Tax Act does Vodafone International Holdings BV v. Union of India come up under?

It is most often cited in judgments turning on Section 143(3), Section 153A, Section 263, Section 147, Section 148, Section 131(1A).

Vodafone International Holdings BV v. Union of India

Q: How many judgments cite Vodafone International Holdings BV v. Union of India?

216 judgments on BharatTax cite Vodafone International Holdings BV v. Union of India (6 SCC 613), spanning 2012 to 2026.

6 SCC 613Supreme Court of India2012#418 most cited

What is Vodafone International Holdings BV v. Union of India authority for?

Tax planning is legitimate only if it is within the framework of law. Colourable devices cannot be part of tax planning, and it is wrong to encourage avoiding tax through dubious methods.

216

judgments rely on this decision, according to BharatTax’s citation analysis of 367,518 Indian tax judgments — from 2012 to 2026.

Also referred to as

Vodafone International Holdings v. Union of India · substance over form · tax planning · colourable devices · avoiding tax · dubious methods · McDowell · 1985 3 SCC 230 · 2012 6 SCC 613

Also reported as

17 Taxmann.com 202204 Taxmann 408

Sections most often in play

Section 143(3)Section 153A Section 263 Section 147 Section 148 Section 131(1A)Section 132 Section 251

Issues it is cited on

place of effective management section 6(3)section 9(1)(ii)section 127(1)section 80ab section 73 substance over form treaty benefits legal expenses ddt clarificatory amendment azadi bachao andolan

Judgments citing Vodafone International Holdings BV v. Union of India

Powertronix Engineering Pvt. Ltd., Kolkata vs. DCIT, CPC, Kolkata

In the result, the appeal of the assessee is allowed

ITA 554/KOL/2021[2017-18]Status: DisposedITAT Kolkata10 Dec 2021AY 2017-18

Bench: Shri P.M. Jagtap, Vice-(Kz) & Shri A.T. Varkey

Section 139(1)Section 2(24)(x)Section 36(1)(va)Section 43B

…biguity in the language of Explanation 3C shall be resolved in favour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner (supra) as followed by judgments of this Court - See Vodafone International Holdings BV v. Union of India, (2012) 6 SCC 613 at paras 60 to 70 per Kapadia, C.J. and para 333, 334 per Radhakrishnan, J.” 3 A.Y. 2017-2018 Powertronix Engineering (P) Limited 10. And according to Ld. A.R. the Ld. CIT(A) erred in holding the later amendment brought in by Finance Act, 2021 to be retrospective and for that proposition he cited the Constitution Bench decision of the Hon’ble S…

M/S Balaji Export Corporation, Kolkata vs. DCIT, Cir. 29, Kolkata

In the result, the appeal of the assessee is allowed

ITA 530/KOL/2021[2019-20]Status: DisposedITAT Kolkata10 Dec 2021AY 2019-20

Bench: Shri P.M. Jagtap(Kz) &Shri A. T. Varkey] Assessment Year: 2019-20

Section 139Section 2(24)(x)Section 36(1)(va)Section 43B

…biguity in the language of Explanation 3C shall be resolved in favour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner (supra) as followed by judgments of this Court - See Vodafone International Holdings BV v. Union of India, (2012) 6 SCC 613 at paras 60 to 70 per Kapadia, C.J. and para 333, 334 per Radhakrishnan, J.” 10. And according to Ld. A.R. the Ld. CIT(A) erred in holding the later amendment brought in by Finance Act, 2021 to be retrospective and for that proposition he cited the Constitution Bench decision of the Hon’ble Supreme Court in the case of CIT vs. Vatika Township Pvt.…

Plasto Electronics Pvt. Ltd., Kolkata vs. DCIT, CPC, Bangalore

In the result, the appeal of the assessee is allowed

ITA 523/KOL/2021[2018-19]Status: DisposedITAT Kolkata10 Dec 2021AY 2018-19

Bench: Shri P.M. Jagtap(Kz) &Shri A. T. Varkey] Assessment Year: 2018-19

Section 139Section 2(24)(x)Section 36(1)(va)Section 43B

…biguity in the language of Explanation 3C shall be resolved in favour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner (supra) as followed by judgments of this Court - See Vodafone International Holdings BV v. Union of India, (2012) 6 SCC 613 at paras 60 to 70 per Kapadia, C.J. and para 333, 334 per Radhakrishnan, J.” 10. And according to Ld. A.R. the Ld. CIT(A) erred in holding the later amendment brought in by Finance Act, 2021 to be retrospective and for that proposition he cited the Constitution Bench decision of the Hon’ble Supreme Court in the case of CIT vs. Vatika Township Pvt.…

Tapan Paul, Kolkata vs. DCIT, CPC, Bangalore

In the result, the appeal of the assessee is allowed

ITA 509/KOL/2021[2018-19]Status: DisposedITAT Kolkata10 Dec 2021AY 2018-19

Bench: Shri P.M. Jagtap(Kz) &Shri A. T. Varkey] Assessment Year: 2018-19

Section 139Section 2(24)(x)Section 36(1)(va)Section 43B

…biguity in the language of Explanation 3C shall be resolved in favour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner (supra) as followed by judgments of this Court - See Vodafone International Holdings BV v. Union of India, (2012) 6 SCC 613 at paras 60 to 70 per Kapadia, C.J. and para 333, 334 per Radhakrishnan, J.” 10. And according to Ld. A.R. the Ld. CIT(A) erred in holding the later amendment brought in by Finance Act, 2021 to be retrospective and for that proposition he cited the Constitution Bench decision of the Hon’ble Supreme Court in the case of CIT vs. Vatika Township Pvt.…

Manjushree Plantations Limited, Kolkata vs. DCIT, Cir. -1, Kolkata

In the result, the appeal of the assessee is allowed

ITA 503/KOL/2021[2013-14]Status: DisposedITAT Kolkata10 Dec 2021AY 2013-14

Bench: Shri P.M. Jagtap, Vice-(Kz) & Shri A.T. Varkey

Section 139(1)Section 2(24)(x)Section 36(1)(va)Section 43B

…biguity in the language of Explanation 3C shall be resolved in favour of the assessee as per Cape Brandy Syndicate v. Inland Revenue Commissioner (supra) as followed by judgments of this Court - See Vodafone International Holdings BV v. Union of India, (2012) 6 SCC 613 at paras 60 to 70 per Kapadia, C.J. and para 333, 334 per Radhakrishnan, J.” 3 A.Y. 2013-2014 Manjushree Plantations Limited 10. And according to Ld. A.R. the Ld. CIT(A) erred in holding the later amendment brought in by Finance Act, 2021 to be retrospective and for that proposition he cited the Constitution Bench decision of the Hon’ble Suprem…