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沃达丰印度服务公司必须支付23亿卢比

一位知情律师告诉《印度经济时报》，未上市的VISPL，前身为“3 Global Services Pvt Ltd”，有责任支付这笔款项并提供担保，可能会在高等法院对法庭的裁决提出异议。

沃达丰印度服务公司必须支付23亿卢比

加尔各答/孟买:周一，所得税上诉法庭(ITAT)批准了一名印度人的有条件延期沃达丰集团实体沃达丰印度服务有限公司(VISPL)在转让定价案件中，指示该公司为有争议的税收要求支付2.3亿卢比，并从一家关联公司提供价值90亿卢比的公司担保。

一位知情律师告诉《印度经济时报》，未上市的VISPL，前身为“3 Global Services Pvt Ltd”，有责任支付这笔款项并提供担保，可能会在高等法院对法庭的裁决提出异议。

孟买税务法庭在7月19日的命令中认为，“允许暂停征收2014-15评估年度的可疑税收和利息要求(1128.46亿卢比)，条件是被评估公司在30天内支付“2.3亿卢比”，大约是有争议的税收要求的20%。它还指示VISPL“提供一家关联公司的公司担保，该公司在印度拥有超过争议需求余额的未支配资产，即90亿卢比。”
．
法庭还驳回了VISPL律师的意见，即其最终母公司提供了35384.8亿卢比的公司担保。沃达丰国际控股有限公司他说，“这与目前的诉讼无关”，因为这是针对2008-09年度的评估。

税务法庭在其措辞强硬的命令中表示，尽管被评估者是一家涉及共享服务业务的小型非上市私营公司，授权资本为3000万卢比，但其重要性在于“它在构建金融交易中发挥的战略作用”沃达丰集团在金融操纵过程中被用作渠道的公司通常会回答这一描述。”

截至发稿时，沃达丰集团、沃达丰Idea和VISPL的律师DMD倡导者没有回应ET的询问。

为了证明其观点，仲裁庭援引了VISPL披露的一项国际交易，其中Max集团董事长Analjit Singh和(妻子)Neelu Singh签署了书面协议，要求VISPL或其提名的人购买辛格夫妇在Scorpio Beverages Pvt Ltd (SBP)实体中持有的任何或全部股份，最多不超过51%。

随后，该命令指出，转让定价官员揭示，vispl提名的实体CGP印度投资公司(CGP - m)是一家总部位于毛里求斯的公司，由CGP-开曼群岛全资拥有，沃达丰过去通过该公司持有沃达丰印度路由。

读也

沃达丰Idea表示，融资谈判仍在继续

印度顶级基金经理押注沃达丰Idea的复兴

因此，由于上述行为，法庭表示，cgp -开曼群岛“能够增加沃达丰印度的股份”，因为Scorpio Beverages“拥有大量股份”电信投资印度私人有限公司该公司持有沃达丰印度的大量股权。”

它补充说，由于cspi - m被提名购买天蝎座饮料51%的股份，它“能够以1241亿卢比购买(以前)沃达丰印度4.53%的股权，而这一股权(当时)的市场价格超过了2285亿卢比”。

此外，ITAT表示，提名CGPI-M收购Scorpio Beverages股票“不是一笔公平交易”，因为它让CGPI-M获得了不适当的优势，可以以远低于市场价格的价格购买沃达丰印度股票。

法庭要求VISPL“充分合作，迅速处理有关上诉”，并警告说，其方面的任何疏忽都将导致“立即撤销暂停”。

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\"Vodafone<\/figure>
Kolkata\/Mumbai: The Income Tax Appellate Tribunal (ITAT) on Monday granted a conditional stay to a Vodafone Group Plc<\/a> entity Vodafone India Services Pvt Ltd<\/a> (VISPL) in a transfer pricing case, directing the company to pay Rs 230 crore towards a disputed tax demand and provide a corporate guarantee from an associate company worth Rs 900 crore.

Unlisted VISPL, formerly `3 Global Services Pvt Ltd\u2019, which is liable to pay the sum and provide the guarantee, is likely to contest the tribunal ruling in a high court, a lawyer familiar with the matter, told ET.

The tax tribunal\u2019s Mumbai bench, in its July 19 order deemed fit \u201cto grant a stay on collection of the impugned tax & interest demands (of Rs 1,128.46 crore) for assessment year 2014-15, on condition that the assessee company pays \u201cRs 230 crore,\u201d or roughly 20% of the disputed tax demand within 30 days. It also directed VISPL to \u201cfurnish a corporate guarantee from an associate company, which has unencumbered assets in India in excess of the balance disputed demands, i.e. Rs 900 crore\u201d
.
The tribunal also rejected the VISPL counsel\u2019s submission that a corporate guarantee of Rs 3,538.48 crore had been provided by its ultimate parent, Vodafone International Holdings BV<\/a>, saying \u201cit was not relevant to the present litigation\u201d as it\u2019s specific to assessment year 2008-09.

<\/div><\/div>The tax tribunal, in its strongly-worded order, said though the assessee is a small unlisted private company involved in the shared services business with an authorised capital of Rs 3 crore, its importance lies in the \u201cstrategic role it played in structuring financial transactions for Vodafone Group<\/a>, a description typically answered by companies used as a conduit in the process of financial manoeuvrings\u201d.

At press time, Vodafone Group Plc, Vodafone Idea and VISPL\u2019s lawyers, DMD Advocates, did not respond to ET\u2019s queries.

To drive home its observations, the tribunal cited an international transaction disclosure by VISPL, wherein Max Group chairman Analjit Singh and (wife) Neelu Singh had written agreements requiring VISPL, or a person nominated by it, to buy any or all of the shares up to 51% held by the Singhs in an entity, Scorpio Beverages Pvt Ltd (SBP).

Subsequently, transfer pricing officers, the order noted, unravelled that the VISPL-nominated entity, CGP India Investments (CGPI-M), was a Mauritius-based company fully owned by CGP-Cayman Islands, via which Vodafone\u2019s holdings in erstwhile Vodafone India<\/a> were routed.

Read also<\/h3>
<\/a><\/div>

Vodafone Idea says fund raising talks continue<\/h4><\/a><\/div>
<\/a><\/div>

India\u2019s top fund managers betting on Vodafone Idea\u2019s revival<\/h4><\/a><\/div><\/div>
Accordingly, due to the above exercise, the tribunal said CGP-Cayman Islands was \u201cable to increase shareholdings in Vodafone India\u201d as Scorpio Beverages \u201cowned substantial shareholding in Telecom Investments India Pvt Ltd<\/a>, which holds significant equity capital of Vodafone India.\u201d

<\/div><\/div>It added that as a result of CGPI-M being nominated to buy 51% of Scorpio Beverages, it was \u201cenabled to buy 4.53% equity in (erstwhile) Vodafone India at Rs 1,241 crore, whereas the market price of this shareholding (then) was Rs 2,285 crores in excess\u201d.

Furthermore, the ITAT said the nomination of CGPI-M to acquire Scorpio Beverages\u2019 shares \u201cwas not an arm\u2019s length transaction,\u201d in that it gave CGPI-M an undue advantage to buy Vodafone India shares at a price way below the market rate.

The tribunal asked VISPL to \u201cfully cooperate in expeditious disposal of the appeal in question,\u201d and warned that any lapses on its part would lead to the \u201cstay standing vacated forthwith.\u201d
<\/div><\/div>
Follow and connect with us on Twitter<\/a>, Facebook<\/a>, Linkedin<\/a>, Youtube<\/a><\/div>","NumberOfSentences":{"minfo":"15.0","minfoseo":"15-0"},"AutomatedReadabilityIndex":{"minfo":"14.0","minfoseo":"14-0"},"LastPublishMilliTime":{"minfo":"1626751055145","minfoseo":"1626751055145"},"ReadabilityGradeLevel":{"minfo":"College","minfoseo":"college"},"GadgetsMarkedReviewed":{"minfo":"0","minfoseo":"0"},"HashCode":{"minfo":"956666014","minfoseo":"956666014"},"latestnewsflag":{"minfo":"1.0","minfoseo":"1-0"},"NumberOfCharacters":{"minfo":"3467.0","minfoseo":"3467-0"},"NumberOfWords":{"minfo":"554.0","minfoseo":"554-0"},"key":[{"keyid":"6354923","value":"vodafone india","smid":"0","keynameseo":"vodafone-india","keytype":"","keycount":"totalcount","weightage":"100"},{"keyid":"457732","value":"Vodafone International Holdings BV","smid":"0","keynameseo":"Vodafone-International-Holdings-BV","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"1551291","value":"Vodafone India Services Pvt Ltd","smid":"0","keynameseo":"Vodafone-India-Services-Pvt-Ltd","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"1858163","value":"Vodafone India Services","smid":"0","keynameseo":"Vodafone-India-Services","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"105732","value":"Vodafone Group Plc","smid":"0","keynameseo":"Vodafone-Group-Plc","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"137231","value":"Vodafone group","smid":"0","keynameseo":"Vodafone-group","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"34974","value":"telecom news","smid":"0","keynameseo":"telecom-news","keytype":"","keycount":"totalcount","weightage":"20"},{"keyid":"11676886","value":"telecom investments india pvt ltd","smid":"0","keynameseo":"telecom-investments-india-pvt-ltd","keytype":"","keycount":"totalcount","weightage":"20"}],"authorsplit":{"author":[{"artau":"Kalyan Parbat","aunameseo":"kalyan-parbat","artauid":"4437","artauemail":"kalyan.kpt@gmail.com","auselfimageid":"4437","auimageid":"004437","auimagelen":"33990","auFullName":"Kalyan Parbat","pubname":"ET","designame":"Assistant Telecom Editor at the Level of Senior Assistant Editor","audetailsxml":{"authordetails":"I have been tracking the telecoms industry for over two decades at ET, and still get a thrill breaking a big one. There's never really a dull moment in telecom, and the diversity of the beat in terms of corporate, regulatory, tech, consumer, brand and legal elements keeps the adrenalin running. Besides telecoms, I love my jazz, old John Ford westerns and plumbing the depths of Sherlockian lore to keep the inspiration flowing. Email : kalyan.parbat@timesgroup.com. Twitter : @kalyanparbatET","details":{"detail":[{"@attributes":{"type":"occupation"}},{"@attributes":{"type":"beat"}}]}},"aulinksxml":{"links":{"link":{"twitter":[],"facebook":[],"googlePlusUrl":[],"contributorUrl":[]}}},"auagencyid":"88675387","auagencyname":"ET Bureau","autype":"GENERAL"},{"artau":"Devina Sengupta","aunameseo":"devina-sengupta","artauid":"479252477","artauemail":"devinafake1@in.com","auselfimageid":"479252477","auimageid":"00479252477","auimagelen":"4566","auFullName":"Devina Sengupta","pubname":"ET","designame":"Assistant Editor","audetailsxml":{"authordetails":"I track the Telecom sector, tussles in India Inc's Business Houses and have reported on the Human Capital market for close to a decade. Now in the Telecom beat, I report on M&As, government policies, consumer behaviour and the legal battles involving investors, shareholders and companies. A degree in psychology and another one in journalism helps me break down a story and cover its impact from multiple perspectives. You can reach me on devina.sengupta@timesgroup.com and on Twitter - @DevinaET","details":{"detail":[{"@attributes":{"type":"occupation"}},{"@attributes":{"type":"beat"}}]}},"aulinksxml":{"links":{"link":{"twitter":[],"facebook":[],"googlePlusUrl":[],"contributorUrl":[]}}},"autype":"GENERAL"}]},"similarlytagged":[{"msid":"94625608","stname":"Reliance Jio's tariff to remain affordable, existing subscribers to get opt-in 5G","artsyn":"\"We will always remain affordable. 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This is Jio's lifetime stand, and will offer more value to customers,\" a top Jio executive who does not wish to be named for the story said.","seolocation":"telecomnews\/jio-to-remain-affordable-existing-subscribers-to-get-opt-in-5g","seolocationalt":"Reliance Jio's tariff to remain affordable, existing subscribers to get opt-in 5G","url_seo":"jio-to-remain-affordable-existing-subscribers-to-get-opt-in-5g"},"94290248":{"msid":"94290248","stname":"Airtel, Jio to dial in 5G services with Rs 400-crore festive ad bonanza","artsyn":"Media planners said while all three telcos - Airtel, Jio and Vi - will have tactical campaigns in the festive quarter, Airtel is slated to lead the media spending in the category.","seolocation":"telecomnews\/airtel-jio-to-dial-in-5g-services-with-rs-400-crore-festive-ad-bonanza","seolocationalt":"Airtel, Jio to dial in 5G services with Rs 400-crore festive ad bonanza","url_seo":"airtel-jio-to-dial-in-5g-services-with-rs-400-crore-festive-ad-bonanza"},"93649428":{"msid":"93649428","stname":"Indus Towers stake sale: Vodafone and Canada's CDPQ in talks","artsyn":"It would also be the largest deal by the Canadian pension fund - that has taken big bets in Indian toll roads, power utilities, among others - in the country till date.","seolocation":"telecomnews\/indus-towers-stake-sale-vodafone-and-canadas-cdpq-in-talks","seolocationalt":"Indus Towers stake sale: Vodafone and Canada's CDPQ in talks","url_seo":"indus-towers-stake-sale-vodafone-and-canadas-cdpq-in-talks"},"93448015":{"msid":"93448015","stname":"Vodafone Idea appoints ex-Jio executive Pravir Kumar as Operations Director","artsyn":"In his new role, the executive will oversee Vi's Uttar Pradesh and Madhya Pradesh & Chandigarh cluster operations. \u200b\u200b","seolocation":"telecomnews\/vodafone-idea-appoints-ex-jio-executive-pravir-kumar-as-operations-director","seolocationalt":"Vodafone Idea appoints ex-Jio executive Pravir Kumar as Operations Director","url_seo":"vodafone-idea-appoints-ex-jio-executive-pravir-kumar-as-operations-director"},"92428645":{"msid":"92428645","stname":"CloudExtel appoints former Vodafone Idea exec Deepak Saxena as SVP of wireline services","artsyn":"\u201cWe are delighted to welcome Deepak Saxena as Senior Vice President, Wireline Services. He will be a part of the core leadership team of CloudExtel and will be responsible for scaling and accelerating NaaS for Telecom Service Providers (TSPs), Internet Service Providers (ISPs), data centres, and prominent OTT players,\u201d the firm said in an update on Linkedin.","seolocation":"telecomnews\/cloudextel-appoints-former-vodafone-idea-exec-deepak-saxena-as-vp-of-wireline-services","seolocationalt":"CloudExtel appoints former Vodafone Idea exec Deepak Saxena as SVP of wireline services","url_seo":"cloudextel-appoints-former-vodafone-idea-exec-deepak-saxena-as-vp-of-wireline-services"},"91929435":{"msid":"91929435","stname":"Allocate unsold spectrum at a price: Vodafone Idea CEO","artsyn":"On his suggestion of allocating unsold spectrum to mobile operators at a price, Takkar said that it can be considered as one of the options. \u201cSo, if you look at the last auction that took place in February 21, there was like 60% spectrum that went unsold\u2026 (So) you might as well allocate\u2026 may be you should consider just giving the spectrum away at a certain price because there\u2019s a price-discovery element,\u201d he said. Takkar further added, \u201cI\u2019m saying that it\u2019s an option which could be looked at. I\u2019m not saying that that\u2019s what I\u2019m advocating for. \u201d","seolocation":"telecomnews\/allocate-unsold-spectrum-at-a-price-vodafone-idea-ceo","seolocationalt":"Allocate unsold spectrum at a price: Vodafone Idea CEO","url_seo":"allocate-unsold-spectrum-at-a-price-vodafone-idea-ceo"},"89950134":{"msid":"89950134","stname":"Former Vodafone Idea exec Reema Jain joins Hero MotoCorp as chief information & digital officer","artsyn":"Jain most recently served as chief digital officer at Vodafone India. 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Airtel, Vodafone Idea and even the telecom department opposed the telecom market leader's application for impleadment.","seolocation":"telecomnews\/jio-applies-to-tdsat-to-be-heard-in-points-of-interconnection-fines-case","seolocationalt":"Jio applies to TDSAT to be heard in points of interconnection fines case","url_seo":"jio-applies-to-tdsat-to-be-heard-in-points-of-interconnection-fines-case"},"87741362":{"msid":"87741362","stname":"Singapore court has stayed India tax dispute proceedings under Dutch BIT: Vodafone","artsyn":"VIHBV and Vodafone Group Plc will continue to defend vigorously any allegation that VIHBV or Vodafone India is liable to pay tax in connection with the transaction with HTIL,\" Vodafone Group said in its half yearly earnings report on Tuesday.","seolocation":"telecomnews\/singapore-court-has-stayed-india-tax-dispute-proceedings-under-dutch-bit-vodafone","seolocationalt":"Singapore court has stayed India tax dispute proceedings under Dutch BIT: Vodafone","url_seo":"singapore-court-has-stayed-india-tax-dispute-proceedings-under-dutch-bit-vodafone"},"87739151":{"msid":"87739151","stname":"Vodafone Idea needs to raise $2.5 billion, double capex to protect RMS, say analysts","artsyn":"\u201cIf Vi has to preserve its current 19% RMS, it will have to raise (an estimated) $2.5 billion in equity and double its capex run-rate,\u201d IIFL Securities said in a note. The brokerage estimates Airtel and Jio\u2019s latest RMS levels at 35% and 40% respectively.","seolocation":"telecomnews\/vodafone-idea-needs-to-raise-2-5-billion-double-capex-to-protect-rms-iifl","seolocationalt":"Vodafone Idea needs to raise $2.5 billion, double capex to protect RMS, say analysts","url_seo":"vodafone-idea-needs-to-raise-2-5-billion-double-capex-to-protect-rms-iifl"},"87711707":{"msid":"87711707","stname":"Vodafone Idea needs at least $1 bln in 6-9 months to repay debt, operate with limited capex: Credit Suisse","artsyn":"The telco has accepted the government's four-year moratorium under which it will pay previous adjusted gross revenue (AGR) and spectrum dues only after FY25-26, which, analysts estimate, may give it a Rs1 lakh crore cash flow relief.","seolocation":"telecomnews\/vodafone-idea-needs-at-least-1-bln-in-6-9-months-to-repay-debt-operate-with-limited-capex-cs","seolocationalt":"Vodafone Idea needs at least $1 bln in 6-9 months to repay debt, operate with limited capex: Credit Suisse","url_seo":"vodafone-idea-needs-at-least-1-bln-in-6-9-months-to-repay-debt-operate-with-limited-capex-cs"},"87638054":{"msid":"87638054","stname":"Facing internal challenges: DoT officials concerned over plan to settle OTSC","artsyn":"The discussion comes at a time when the latest legal opinion sought by the DoT says it has the power to settle cases such as the OTSC out of court.","seolocation":"telecomnews\/facing-internal-challenges-dot-officials-concerned-over-plan-to-settle-otsc","seolocationalt":"Facing internal challenges: DoT officials concerned over plan to settle OTSC","url_seo":"facing-internal-challenges-dot-officials-concerned-over-plan-to-settle-otsc"},"86955181":{"msid":"86955181","stname":"Kumar Mangalam Birla may infuse own capital into Vodafone Idea","artsyn":"A person familiar with the matter said that the promoter infusion is likely to be much lesser than Rs 10,000 crore that has been reported in some media.","seolocation":"telecomnews\/kumar-mangalam-birla-may-infuse-own-capital-into-vodafone-idea","seolocationalt":"Kumar Mangalam Birla may infuse own capital into Vodafone Idea","url_seo":"kumar-mangalam-birla-may-infuse-own-capital-into-vodafone-idea"},"86002946":{"msid":"86002946","stname":"Vodafone Idea in a 'difficult phase', hope govt supports: Kapania","artsyn":"\u201cAs the industry continues to remain under unsustainable financial duress, your company is hopeful that the government will provide the necessary support to address all structural issues faced by the sector,\" Kapania said in his first letter to shareholders since replacing Kumar Mangalam Birla as chairman of the struggling carrier.","seolocation":"telecomnews\/vil-flags-industrys-unsustainable-financial-duress-hopes-for-govt-support","seolocationalt":"Vodafone Idea in a 'difficult phase', hope govt supports: Kapania","url_seo":"vil-flags-industrys-unsustainable-financial-duress-hopes-for-govt-support"},"85919880":{"msid":"85919880","stname":"Franklin Templeton Mutual Fund gets Rs 149 crore from Vodafone Idea","artsyn":"Franklin Templeton Mutual Fund has said it received a payment of nearly Rs 149 crore from Vodafone Idea Ltd as interest on its securities investment, which will be distributed among investors of the segregated portfolios.","seolocation":"telecomnews\/franklin-templeton-mutual-fund-gets-rs-149-crore-from-vodafone-idea","seolocationalt":"Franklin Templeton Mutual Fund gets Rs 149 crore from Vodafone Idea","url_seo":"franklin-templeton-mutual-fund-gets-rs-149-crore-from-vodafone-idea"},"85705741":{"msid":"85705741","stname":"After Jio, Google now in talks to make large investments in Airtel","artsyn":"The contours of the partnership are being worked upon for months as top executives from both companies, and their internal and external legal and M&A teams are thrashing out the finer points of the arrangement.","seolocation":"telecomnews\/after-jio-google-now-in-talks-to-make-large-investments-in-airtel","seolocationalt":"After Jio, Google now in talks to make large investments in Airtel","url_seo":"after-jio-google-now-in-talks-to-make-large-investments-in-airtel"},"85361421":{"msid":"85361421","stname":"What happens to subscribers if Vodafone Idea dies, and other key questions","artsyn":"From being the biggest telecom company in India post their merger with over 40 crore customers, today Vodafone Idea is the third-largest, still with a sizeable 26.8 crore consumers. If it files for bankruptcy, there will be a near-panic situation as customers will scramble to migrate to Jio or Airtel or BSNL\/MTNL.","seolocation":"telecomnews\/what-happens-to-subscribers-if-vodafone-idea-dies-and-other-key-questions","seolocationalt":"What happens to subscribers if Vodafone Idea dies, and other key questions","url_seo":"what-happens-to-subscribers-if-vodafone-idea-dies-and-other-key-questions"},"85229833":{"msid":"85229833","stname":"Jio may not be able to replicate Indian success in Holland, says UBS","artsyn":"Newswire report says RIL weighing bid for T-Mobile Netherlands.","seolocation":"telecomnews\/jio-may-not-be-able-to-replicate-indian-success-in-holland-says-ubs","seolocationalt":"Jio may not be able to replicate Indian success in Holland, says UBS","url_seo":"jio-may-not-be-able-to-replicate-indian-success-in-holland-says-ubs"}}}}" data-news-images="[{"msid":"84572635","msname":"Telecom-","msnameseo":"telecom-","mediatype":"2","artdate":"2021-07-15 21:06:00.0","caption":""}]" data-newsletter-by="0" data-newsletter-date="a" data-hasbottomcarousel="" data-alldetailsopen="0" data-multipleanalyticshit="" data-deeplink="https://ettelecom.app.link?$deeplink_path=" data-socialshareformat="default">
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