On 10 October 2014, The Indian High Court in Bombay ruled on whether or not Vodafone's issuance of equity shares to its nonresident holding company gives rise to Indian tax and subject to the country's transfer pricing rules.
The case involved a 2008 issuance of shares at a premium by Vodafone India Services Pvt. Ltd. to its Mauritius-based holding company. In its tax return, Vodafone India reported the arrangement as a non-taxable international transaction. The Indian tax authorities subseq…