$\"\"$ By Ashwin Mohan, ET Bureau
\n
In a fresh setback for British telecom<\/a> giant Vodafone<\/a> which is embroiled in talks with the government to settle a Rs 20,000 cr tax spat over the 2007 Vodafone-Hutchison deal, the income tax<\/a> department has issued a demand notice of Rs 3700 cr against the MNC's Indian arm on Wednesday, two people familiar with the development told ET NOW.
\n
\nET NOW was the first to report the development.
\n
\n\"A final assessment order and a notice of demand seeking Rs 3700 crore in taxes ( including interest) has been sent to Vodafone India Services Private Limited. The company has been given a time-frame of 30 days to comply with the I-T proceedings or approach the appropriate forum for relief. This development is part of the assessment proceedings for 2008-09 and follows an earlier draft transfer pricing order that sought to add Rs 8500 cr to the company's taxable income,\" said one of the two sources mentioned above.
\n
\nIn response to an e-mail query, Vodafone spokesperson Ben Padovan told ET NOW , \" \"Vodafone disagrees with the Dispute Resolution Panel decision relating to the Transfer Pricing Order which Vodafone received in December 2011. Vodafone maintains that there is no tax payable on this transaction and the company will file an appeal before the tax appeal tribunal as soon as possible.
\n
\nThe facts of this case - including the transaction structure - were examined in considerable detail by India's Supreme Court, which delivered an unambiguous judgment affirming that there is indeed no tax due. Vodafone will continue to strongly defend its position against this Order.\"
\n
\n\" This development will add to Vodafone's existing legal battles in India. It calls for effective legal strategies to seek an early resolution,\" says Sanjay Sanghvi, tax partner, Khaitan & Co.
\n
\nA senior finance ministry ministry official said , \" Due to past precedents, the revenue department is expected to continue to be active in the transfer pricing space.\"
\n
\nEarlier in September, the Bombay High Court while dismissing Vodafone India's writ petition had instructed the tax department not to serve the final assessment order and directions of the dispute resolution panel till Dec 17th. The company had questioned the jurisdiction of the revenue authorities to add Rs 8,500 crore to the taxable income of its Indian arm following a scrutiny of transactions by its ( Vodafone India) call centre business.
\n
\nIn January 2012, Vodafone had also moved the dispute resolution panel of the income tax<\/a> department in the same case.
\n
\nTransfer price refers to the actual price at which a transaction takes place between two related parties, usually belonging to the same group. Multinational and transnational firms use transfer pricing to allocate revenue between different divisions.\n\n<\/body>","next_sibling":[{"msid":27581125,"title":"ZTE says India operations unaffected in Vringo patents row","entity_type":"ARTICLE","link":"\/news\/industry\/zte-says-india-operations-unaffected-in-vringo-patents-row\/27581125","category_name":null,"category_name_seo":"industry"}],"related_content":[],"msid":27627640,"entity_type":"ARTICLE","title":"Vodafone gets Rs 3,700-cr tax bill from I-T department","synopsis":"The income tax department has issued a demand notice of Rs 3700 cr. Vodafone has been given a time-frame of 30 days to comply with the I-T proceedings or approach the appropriate forum for relief.","titleseo":"industry\/vodafone-gets-rs-3700-cr-tax-bill-from-i-t-department","status":"ACTIVE","authors":[{"author_name":"Ashwin Mohan","author_link":"\/author\/19735\/ashwin-mohan","author_image":"https:\/\/etimg.etb2bimg.com\/authorthumb\/19735.cms?width=100&height=100","author_additional":{"thumbsize":false,"msid":19735,"author_name":"Ashwin Mohan","author_seo_name":"ashwin-mohan","designation":"Editor","agency":false}}],"Alttitle":{"minfo":""},"artag":"ET Now","artdate":"2013-12-19 09:43:55","lastupd":"2013-12-19 10:42:01","breadcrumbTags":["industry","Income Tax","Telecom","Vodafone","IT department","Tax evasion"],"secinfo":{"seolocation":"industry\/vodafone-gets-rs-3700-cr-tax-bill-from-i-t-department"}}" data-authors="[" ashwin mohan"]" data-category-name="Industry" data-category_id="18" data-date="2013-12-19" data-index="article_1">

行业

沃达丰从它得到Rs 3700 - cr税单

所得税部门发布了一份需求通知Rs 3700 cr。沃达丰已30天的时间来遵守它的时间框架程序或方法适当的论坛寻求帮助。

更新2013年12月19日,42点坚持

由Ashwin Mohan等

在英国一个新的挫折电信巨大的沃达丰(Vodafone)这是卷入与政府谈判,以解决Rs 20000 cr税收2007 Vodafone-Hutchison交易纠纷,所得税部门已发布了一份需求通知Rs 3700 cr周三对印度跨国公司的子公司,两位知情人士告诉发展等。

现在是第一个报告的发展。

“最后的评估顺序和注意的需求寻求3700卢比的税(包括利息)已向沃达丰印度私人有限的服务。公司有30天的时间框架符合它程序或方法适当的论坛寻求帮助。这种发展是2008 - 09年的评估程序的一部分,较早的一份草案转让定价以便试图添加Rs 8500 cr公司的应纳税所得额,说上面提到的两个来源之一。

在回应电子邮件查询,沃达丰(Vodafone)发言人本Padovan告诉ET现在,”“沃达丰(Vodafone)不同意有关的争端解决小组决定的转让定价秩序沃达丰2011年12月。沃达丰(Vodafone)认为,这笔交易没有应纳税款,税务上诉前的公司将提起上诉法庭尽快。

这种情况下的事实,包括交易结构,是由印度最高法院相当详细地检查,传递一个明确的判断肯定,确实是没有税。沃达丰将继续坚决捍卫自己的立场反对。”

”这一发展将使沃达丰在印度现有的法律纠纷。它需要有效的法律策略寻求早日解决,“Sanjay Sanghvi说,税务部合伙人,比& Co。

希腊财政部一位高级官员说,“由于过去的先例,收入部门预计将继续活跃在转让定价空间。”

9月早些时候,印度孟买高等法院,同时抛弃了沃达丰的命令请愿书已经指示税务部门不服务的最终评估顺序和方向争端解决小组到12月17日。公司质疑当局管辖收入增加8500卢比的应纳税所得额后其印度子公司交易的审查(沃达丰印度)呼叫中心业务。

2012年1月,沃达丰也感动的争端解决小组所得税部门在同一案件中。

转让价格指的是实际价格两个关联方之间的交易发生,通常属于同一组。跨国公司和跨国公司使用转移定价不同部门之间的收入分配。

发布于2013年12月19日09:43点坚持

$\"\"$ By Ashwin Mohan, ET Bureau
\n
In a fresh setback for British telecom<\/a> giant Vodafone<\/a> which is embroiled in talks with the government to settle a Rs 20,000 cr tax spat over the 2007 Vodafone-Hutchison deal, the income tax<\/a> department has issued a demand notice of Rs 3700 cr against the MNC's Indian arm on Wednesday, two people familiar with the development told ET NOW.
\n
\nET NOW was the first to report the development.
\n
\n\"A final assessment order and a notice of demand seeking Rs 3700 crore in taxes ( including interest) has been sent to Vodafone India Services Private Limited. The company has been given a time-frame of 30 days to comply with the I-T proceedings or approach the appropriate forum for relief. This development is part of the assessment proceedings for 2008-09 and follows an earlier draft transfer pricing order that sought to add Rs 8500 cr to the company's taxable income,\" said one of the two sources mentioned above.
\n
\nIn response to an e-mail query, Vodafone spokesperson Ben Padovan told ET NOW , \" \"Vodafone disagrees with the Dispute Resolution Panel decision relating to the Transfer Pricing Order which Vodafone received in December 2011. Vodafone maintains that there is no tax payable on this transaction and the company will file an appeal before the tax appeal tribunal as soon as possible.
\n
\nThe facts of this case - including the transaction structure - were examined in considerable detail by India's Supreme Court, which delivered an unambiguous judgment affirming that there is indeed no tax due. Vodafone will continue to strongly defend its position against this Order.\"
\n
\n\" This development will add to Vodafone's existing legal battles in India. It calls for effective legal strategies to seek an early resolution,\" says Sanjay Sanghvi, tax partner, Khaitan & Co.
\n
\nA senior finance ministry ministry official said , \" Due to past precedents, the revenue department is expected to continue to be active in the transfer pricing space.\"
\n
\nEarlier in September, the Bombay High Court while dismissing Vodafone India's writ petition had instructed the tax department not to serve the final assessment order and directions of the dispute resolution panel till Dec 17th. The company had questioned the jurisdiction of the revenue authorities to add Rs 8,500 crore to the taxable income of its Indian arm following a scrutiny of transactions by its ( Vodafone India) call centre business.
\n
\nIn January 2012, Vodafone had also moved the dispute resolution panel of the income tax<\/a> department in the same case.
\n
\nTransfer price refers to the actual price at which a transaction takes place between two related parties, usually belonging to the same group. Multinational and transnational firms use transfer pricing to allocate revenue between different divisions.\n\n<\/body>","next_sibling":[{"msid":27581125,"title":"ZTE says India operations unaffected in Vringo patents row","entity_type":"ARTICLE","link":"\/news\/industry\/zte-says-india-operations-unaffected-in-vringo-patents-row\/27581125","category_name":null,"category_name_seo":"industry"}],"related_content":[],"msid":27627640,"entity_type":"ARTICLE","title":"Vodafone gets Rs 3,700-cr tax bill from I-T department","synopsis":"The income tax department has issued a demand notice of Rs 3700 cr. Vodafone has been given a time-frame of 30 days to comply with the I-T proceedings or approach the appropriate forum for relief.","titleseo":"industry\/vodafone-gets-rs-3700-cr-tax-bill-from-i-t-department","status":"ACTIVE","authors":[{"author_name":"Ashwin Mohan","author_link":"\/author\/19735\/ashwin-mohan","author_image":"https:\/\/etimg.etb2bimg.com\/authorthumb\/19735.cms?width=100&height=100","author_additional":{"thumbsize":false,"msid":19735,"author_name":"Ashwin Mohan","author_seo_name":"ashwin-mohan","designation":"Editor","agency":false}}],"Alttitle":{"minfo":""},"artag":"ET Now","artdate":"2013-12-19 09:43:55","lastupd":"2013-12-19 10:42:01","breadcrumbTags":["industry","Income Tax","Telecom","Vodafone","IT department","Tax evasion"],"secinfo":{"seolocation":"industry\/vodafone-gets-rs-3700-cr-tax-bill-from-i-t-department"}}" data-news_link="//www.iser-br.com/news/industry/vodafone-gets-rs-3700-cr-tax-bill-from-i-t-department/27627640">