VODAFONE TAX CASE | VODAFONE HUTCH CASE | VODAFONE TAX CASE STUDYSonalS15
The Vodafone Tax Case is one of the most controversial Tax dispute in the history of Indian Income Tax Law.
FOR FREELANCE POWERPOINT PRESENTATIONS ON ANY TOPIC, MAIL ME AT sonalkumari8991@gmail.com
Vodafone and hutch merged in 2007, which is the second largest Merger with a deal value of $11.1 billion. The pre and post merger key financial ratios of both the companies are presented.
VODAFONE TAX CASE | VODAFONE HUTCH CASE | VODAFONE TAX CASE STUDYSonalS15
The Vodafone Tax Case is one of the most controversial Tax dispute in the history of Indian Income Tax Law.
FOR FREELANCE POWERPOINT PRESENTATIONS ON ANY TOPIC, MAIL ME AT sonalkumari8991@gmail.com
Vodafone and hutch merged in 2007, which is the second largest Merger with a deal value of $11.1 billion. The pre and post merger key financial ratios of both the companies are presented.
A study on Vijay Mallya Scam Case: Vijay Vittal Mallya, once known to you and me as ‘The King of Good Times’ or also dubbed ‘ The playboy of the East’ was born to the Indian Entrepreneur Vittal Mallya in 1955. Vittal Mallya was largely known for the role played as the director of United Breweries (UB) Group which he achieved at the age of 23. Following his father’s sudden demise Vijay Mallya became chairman of the UB Group.Vijay Mallya was always known for his flamboyant and posh lifestyle. A testament to these were the lavish New Year Parties at his Kingfisher Villa in Goa or the birthday bashes thrown on his luxurious Yacht ‘ The Indian Empress’.
Punjab National Bank Fraud (Nirav Modi Scam) ppt presentation slideshareFatema Tandiwala
A case study presentation on Punjab National Bank scam (Nirav Modi)
India's second largest state-owned lender Punjab National Bank disclosed on Feb. 14, 2018 that it was the victim of the country’s largest bank fraud.
PNB revealed that fraudulent transactions by billionaire jeweler Nirav Modi and related entities amounted to $1.77 billion or over Rs 11,400 crore.
The key accused in the case were jeweler and designer Nirav Modi, his maternal uncle Mehul Choksi, and other relatives and some PNB employees.
Nirav Modi and his relatives escaped India in early 2018, days before the news of the scam became public.
PNB scam has been dubbed as the biggest fraud in India's banking history.
Does Corporate Governance really stays the same in the reality as it's been explained to students...?
Such cases really raise many questions on that note.
A study on Vijay Mallya Scam Case: Vijay Vittal Mallya, once known to you and me as ‘The King of Good Times’ or also dubbed ‘ The playboy of the East’ was born to the Indian Entrepreneur Vittal Mallya in 1955. Vittal Mallya was largely known for the role played as the director of United Breweries (UB) Group which he achieved at the age of 23. Following his father’s sudden demise Vijay Mallya became chairman of the UB Group.Vijay Mallya was always known for his flamboyant and posh lifestyle. A testament to these were the lavish New Year Parties at his Kingfisher Villa in Goa or the birthday bashes thrown on his luxurious Yacht ‘ The Indian Empress’.
Punjab National Bank Fraud (Nirav Modi Scam) ppt presentation slideshareFatema Tandiwala
A case study presentation on Punjab National Bank scam (Nirav Modi)
India's second largest state-owned lender Punjab National Bank disclosed on Feb. 14, 2018 that it was the victim of the country’s largest bank fraud.
PNB revealed that fraudulent transactions by billionaire jeweler Nirav Modi and related entities amounted to $1.77 billion or over Rs 11,400 crore.
The key accused in the case were jeweler and designer Nirav Modi, his maternal uncle Mehul Choksi, and other relatives and some PNB employees.
Nirav Modi and his relatives escaped India in early 2018, days before the news of the scam became public.
PNB scam has been dubbed as the biggest fraud in India's banking history.
Does Corporate Governance really stays the same in the reality as it's been explained to students...?
Such cases really raise many questions on that note.
Vodafone acquired HTIL (Hutchison Telecom International)’s 67% stake in Hutchison-Essar.
Relations between Hutchison Telecom and the Essar group of India will be key to the sale of Hutch's 67% stake in Hutch-Essar.
SCRAPPING OF RETRO TAX PROVISIONS : A REVIVAL OF OVERSEAS INTEREST IN INDIADVSResearchFoundatio
Key Takeaways:
- Scrapping of Restrospective effect of Taxation
- Indirect transfer of assets not taxable before 28th May 2012
- Vodafone case analysis
- Draft notification to implement the amendment
Fast track notes on income tax.Total Tax With maximum Effective Question'sEducation At The Edge
The Income-tax Act, 1961,Income under the head
salary,Income under the head house property,
Income under the head business and profession,
Income under the head capital gains,
Income under the head other sources,Revenue Vs Capital, RESIDENTIAL STATUS,CALCULATION OF INCOME TAX,CLUBBING OF INCOMES,SET OFF & CARRY FORWARD OF LOSSES,INCOME FROM AGRICULTURE,DEDUCTIONS FROM GTI,EXEMPTED INCOMES,ASSESSMENT PROCEDURE,ADVANCE TAX AND INTEREST PAYABLE ,TAX DEDUCTED AT SOURCE,CHARITABLE OR RELIGIOUS TRUSTS,SERVICE TAX,VALUE ADDED TAX (VAT),
THIS IS MY FIRST PRESENTATION OF BLACK MONEY BILL. I WILL PUT MY SINCERE EFFORTS AND TRIED MY BEST TO MAKE THIS PRESENTATION USEFUL AND EASILY UNDERSTANDABLE.
THANKS
CA DEEPAK KAPOOR
DIRECT TAX CONSULTANT
Here we are with the Thirtieth successive issue of our monthly ‘Missive’.
We trust you will enjoy reading this Missive, even while soaking in the contents. We would very much appreciate your feedback which consistently helps us in improving and upgrading the contents.
- The Asian landscape - uncertainty in the near term
- Structuring considerations
- Risk allocation amongst parties
Prabhu Narasimhan, Counsel, White & Case
Peita Menton, Partner, White & Case
how can i use my minded pi coins I need some funds.DOT TECH
If you are interested in selling your pi coins, i have a verified pi merchant, who buys pi coins and resell them to exchanges looking forward to hold till mainnet launch.
Because the core team has announced that pi network will not be doing any pre-sale. The only way exchanges like huobi, bitmart and hotbit can get pi is by buying from miners.
Now a merchant stands in between these exchanges and the miners. As a link to make transactions smooth. Because right now in the enclosed mainnet you can't sell pi coins your self. You need the help of a merchant,
i will leave the telegram contact of my personal pi merchant below. 👇 I and my friends has traded more than 3000pi coins with him successfully.
@Pi_vendor_247
how to swap pi coins to foreign currency withdrawable.DOT TECH
As of my last update, Pi is still in the testing phase and is not tradable on any exchanges.
However, Pi Network has announced plans to launch its Testnet and Mainnet in the future, which may include listing Pi on exchanges.
The current method for selling pi coins involves exchanging them with a pi vendor who purchases pi coins for investment reasons.
If you want to sell your pi coins, reach out to a pi vendor and sell them to anyone looking to sell pi coins from any country around the globe.
Below is the contact information for my personal pi vendor.
Telegram: @Pi_vendor_247
how to sell pi coins on Bitmart crypto exchangeDOT TECH
Yes. Pi network coins can be exchanged but not on bitmart exchange. Because pi network is still in the enclosed mainnet. The only way pioneers are able to trade pi coins is by reselling the pi coins to pi verified merchants.
A verified merchant is someone who buys pi network coins and resell it to exchanges looking forward to hold till mainnet launch.
I will leave the telegram contact of my personal pi merchant to trade with.
@Pi_vendor_247
USDA Loans in California: A Comprehensive Overview.pptxmarketing367770
USDA Loans in California: A Comprehensive Overview
If you're dreaming of owning a home in California's rural or suburban areas, a USDA loan might be the perfect solution. The U.S. Department of Agriculture (USDA) offers these loans to help low-to-moderate-income individuals and families achieve homeownership.
Key Features of USDA Loans:
Zero Down Payment: USDA loans require no down payment, making homeownership more accessible.
Competitive Interest Rates: These loans often come with lower interest rates compared to conventional loans.
Flexible Credit Requirements: USDA loans have more lenient credit score requirements, helping those with less-than-perfect credit.
Guaranteed Loan Program: The USDA guarantees a portion of the loan, reducing risk for lenders and expanding borrowing options.
Eligibility Criteria:
Location: The property must be located in a USDA-designated rural or suburban area. Many areas in California qualify.
Income Limits: Applicants must meet income guidelines, which vary by region and household size.
Primary Residence: The home must be used as the borrower's primary residence.
Application Process:
Find a USDA-Approved Lender: Not all lenders offer USDA loans, so it's essential to choose one approved by the USDA.
Pre-Qualification: Determine your eligibility and the amount you can borrow.
Property Search: Look for properties in eligible rural or suburban areas.
Loan Application: Submit your application, including financial and personal information.
Processing and Approval: The lender and USDA will review your application. If approved, you can proceed to closing.
USDA loans are an excellent option for those looking to buy a home in California's rural and suburban areas. With no down payment and flexible requirements, these loans make homeownership more attainable for many families. Explore your eligibility today and take the first step toward owning your dream home.
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the Telegram username
@Pi_vendor_247
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what is the future of Pi Network currency.DOT TECH
The future of the Pi cryptocurrency is uncertain, and its success will depend on several factors. Pi is a relatively new cryptocurrency that aims to be user-friendly and accessible to a wide audience. Here are a few key considerations for its future:
Message: @Pi_vendor_247 on telegram if u want to sell PI COINS.
1. Mainnet Launch: As of my last knowledge update in January 2022, Pi was still in the testnet phase. Its success will depend on a successful transition to a mainnet, where actual transactions can take place.
2. User Adoption: Pi's success will be closely tied to user adoption. The more users who join the network and actively participate, the stronger the ecosystem can become.
3. Utility and Use Cases: For a cryptocurrency to thrive, it must offer utility and practical use cases. The Pi team has talked about various applications, including peer-to-peer transactions, smart contracts, and more. The development and implementation of these features will be essential.
4. Regulatory Environment: The regulatory environment for cryptocurrencies is evolving globally. How Pi navigates and complies with regulations in various jurisdictions will significantly impact its future.
5. Technology Development: The Pi network must continue to develop and improve its technology, security, and scalability to compete with established cryptocurrencies.
6. Community Engagement: The Pi community plays a critical role in its future. Engaged users can help build trust and grow the network.
7. Monetization and Sustainability: The Pi team's monetization strategy, such as fees, partnerships, or other revenue sources, will affect its long-term sustainability.
It's essential to approach Pi or any new cryptocurrency with caution and conduct due diligence. Cryptocurrency investments involve risks, and potential rewards can be uncertain. The success and future of Pi will depend on the collective efforts of its team, community, and the broader cryptocurrency market dynamics. It's advisable to stay updated on Pi's development and follow any updates from the official Pi Network website or announcements from the team.
when will pi network coin be available on crypto exchange.DOT TECH
There is no set date for when Pi coins will enter the market.
However, the developers are working hard to get them released as soon as possible.
Once they are available, users will be able to exchange other cryptocurrencies for Pi coins on designated exchanges.
But for now the only way to sell your pi coins is through verified pi vendor.
Here is the telegram contact of my personal pi vendor
@Pi_vendor_247
Even tho Pi network is not listed on any exchange yet.
Buying/Selling or investing in pi network coins is highly possible through the help of vendors. You can buy from vendors[ buy directly from the pi network miners and resell it]. I will leave the telegram contact of my personal vendor.
@Pi_vendor_247
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Empowering the Unbanked: The Vital Role of NBFCs in Promoting Financial Inclu...Vighnesh Shashtri
In India, financial inclusion remains a critical challenge, with a significant portion of the population still unbanked. Non-Banking Financial Companies (NBFCs) have emerged as key players in bridging this gap by providing financial services to those often overlooked by traditional banking institutions. This article delves into how NBFCs are fostering financial inclusion and empowering the unbanked.
how can I sell pi coins after successfully completing KYCDOT TECH
Pi coins is not launched yet in any exchange 💱 this means it's not swappable, the current pi displaying on coin market cap is the iou version of pi. And you can learn all about that on my previous post.
RIGHT NOW THE ONLY WAY you can sell pi coins is through verified pi merchants. A pi merchant is someone who buys pi coins and resell them to exchanges and crypto whales. Looking forward to hold massive quantities of pi coins before the mainnet launch.
This is because pi network is not doing any pre-sale or ico offerings, the only way to get my coins is from buying from miners. So a merchant facilitates the transactions between the miners and these exchanges holding pi.
I and my friends has sold more than 6000 pi coins successfully with this method. I will be happy to share the contact of my personal pi merchant. The one i trade with, if you have your own merchant you can trade with them. For those who are new.
Message: @Pi_vendor_247 on telegram.
I wouldn't advise you selling all percentage of the pi coins. Leave at least a before so its a win win during open mainnet. Have a nice day pioneers ♥️
#kyc #mainnet #picoins #pi #sellpi #piwallet
#pinetwork
2. The tax dispute between
; and
in connection with taxability of the $ 11.2 billion
is one of the biggest controversies in Indian history.
The quantum of tax demand by the Indian Revenue
Authorities in this particular case was around
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3. – A merger involves the mutual decision of
two companies to combine and become one entity.
Eg. A + B = AB
– Acquisition is purchase of one
company by another in which no new company is
formed. Eg. A + B = A
• Merger is like two persons getting married.
• Acquisition is like an animal eats any other.
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4. A tax heaven is a
Wikipedia
state, country or territory where
certain taxes are levied at a low rates or not at all.
•
•
•
•
•
Switzerland
Cayman Islands
Luxembourg
Hong Kong
USA
•
•
•
•
•
Singapore
Jersey
Japan
Germany
Bahrain
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TheRichest.Com
6. Sold 100% holding of CGP to VIH
HTIL
VIH
CGP
HEL
Vodafone Essar Limited
VEL
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turned to
7. CGP is a dummy company
CGP is situated in Cayman Islands, which is a tax heaven.
VIH wanted to acquire HEL.
To save Tax, VIH opted to acquire CGP, holding Company of HEL.
Now VIH is neither liable to pay tax
- in India because they have made no transaction in India
nor
- in Mauritius because it’s a tax heaven.
Conclusion: Vodafone acquires Hutch in India with Nil Tax Liability.
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8. Indian Revenue Authorities’ Opinion
CGP was
created to
take benefits
of Tax
Exemption.
Concept
of
Substance Over Form
Transaction was to
transfer Rights
in
The Indian Revenue
Authorities alleged that
to
HEL
VEL
VIH, had failed to
Deduct Tax on the
payment of
Hence, sought to assess tax in its hand
consideration made to as a taxpayer in default and it issued a
HTIL.
notice to Vodafone.
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9. Vodafone petition to HC and SC
Instead of responding to the Notice of Indian Revenue
Authorities, VIH filed a writ petition to the Honourable Bombay
High Court challenging jurisdiction of Income Tax Department.
December 2008
The Honourable Bombay High Court upheld the matter
in favour of Indian Revenue Authorities.
VIH filed Special Leave Petition (SLP) before the Honourable
Supreme Court of India. The Supreme Court disposed the case with
a direction to Tax Authorities to decide the preliminary issue of
jurisdiction.
January 2009
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10. DecisionbyIndianTaxAuthorities and HC
CGP was a mere holding company and was not engaged into
any business in Cayman Islands, thus, the situs of shares
existed where the “underlying assets” i.e. in India.
Further, HTIL had extinguished its right of control over HEL and
extinguishment of “Rights and Entitlements” constituted as
“Capital Assets”.
After going through the terms of Share Purchase Agreement
and other documents, it can be interpreted that the intention
of the parties was ultimately to transfer the controlling
interest in HEL which was situated in India.
The Tax Authorities passed an order under section 201 holding
that they had jurisdiction to proceed against Vodafone for
failure to deduct tax.
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May 2010
11. Vodafone Petition to HC and SC (II)
Vodafone filed a writ petition to the Bombay High Court
challenging the order of Income Tax Authorities.
September 2010
The Bombay High Court dismissed Vodafone’s writ petition
against the order of the Tax Authorities.
Vodafone filed Special Leave Petition (SLP) before the Honourable
Supreme Court of India. The Supreme Court admitted the SLP and
directed Vodafone to deposit Rs. 2,500 crore and provide a bank
guarantee for the balance Rs. 8,500 crore.
November 2010
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12. The Supreme Court’s Decision
The Indian Revenue Authorities had no jurisdiction to tax the
foreign transactions, as sale of shares was in Cayman Island.
Transfer of shares in CGP doesn’t amount to transfer of Capital
Asset situated in India, as per Section 9(1)(i).
The transfer of “Rights and Entitlements” (Controlling Interest) is
not covered in Definition of “Capital Assets” under section 2(14).
As Capital Asset is not taxable in India, so there is no question of
Deducting Tax at Source under section 195(1).
The Supreme Court reversed the decision of Bombay High Court.
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January 2012
13. Retrospective Amendments in Tax Law
Certain Retrospective Amendments were made in Tax Law by
Finance Act 2012 to nullify the judgment of the Supreme Court.
Section 9(1)(i)
Income Deemed to
Accrued or arise in India
Section 2(14)
Section 2(47)
Definition of Capital Assets
Definition of Transfer
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14. SECTION 9(1)(i)
Applicable w.e.f April 1, 1961
All incomes accrued or arise, whether directly or indirectly
through transfer of a “Capital Asset” situated in India.
Co-relate with case
Explanation for Capital Assets:
A Capital Asset being any share in any Entity (whether
registered outside India) deemed to be situated in India,
Shares of CGP were registered
outside India.
if the share derives its value substantially from the asset
located in India.
But the shares derive its value
substantially from the asset
located in India.
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15. Explanation to SECTION 2(14)
Applicable w.e.f April 1, 1961
Co-relate with case
Explanation to Section 2(14):
“Property” includes and shall be deemed to have always
included:
- Any rights in Indian Company
- Any rights in relation to an Indian Company
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HTIL have rights in
Indian Co. (HEL)
16. Explanation to SECTION 2(47)
Applicable w.e.f April 1, 1961
Explanation to Section 2(47):
“Transfers” includes and shall be deemed to have always
included:
- Disposing of or parting with an asset or any interest
therein
- Creating any interest in any asset in any
manner whether indirectly or otherwise
- By way of an agreement (whether entered into
in India or outside India) or otherwise
- Notwithstanding that such transfer of rights have
been characterized as being effected or dependent
upon or flowing from the transfer of share of a
company registered or incorporated outside India.
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HTIL transferred rights in
Indian Co. to
Vodafone, indirectly
Vodafone created interest
in asset in India
By way of an agreement
entered outside India
Co-relate with case
17. The Second Phase of Dispute
is about to start.
Prepared byRohit Jain (CA-Final)
iRohit@live.in
www.irohitjain.blogspot.com
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