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In Vodafone International Holdings B.V. v. Union of India [S.L.P. (C) No. 26529 of 2010], the Supreme Court of India ultimately held that:
Answer & Solution
Correct answer: A.
1. The Lesson 1 paragraph on the Vodafone case reproduces the Supreme Court's holding.
2. The Court set aside the Bombay High Court's judgment directing Vodafone to pay INR 110 billion withholding tax.
3. The Court recognised the corporate-veil principle and held that the transaction was outside India's territorial tax jurisdiction.
4. The Court laid down a six-factor test for distinguishing legitimate holding structures from sham transactions.
_Source: ICSI CS Executive Paper 2 (Company Law) — Lesson 1: Introduction to Company Law, pp. 2-35._
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