<h1>India's Supreme Court Rules Vodafone's Offshore Share Sale Not Taxable, Citing Territorial Tax Limits and Section 9.</h1> The Supreme Court of India ruled in favor of Vodafone International Holdings B.V., determining that the capital gains from the sale of CGP's share capital, a Cayman Islands company, are not taxable under Indian law. The transaction was between two non-resident entities, HTIL and VIH, and occurred outside India, thus falling outside India's territorial tax jurisdiction. The court emphasized the importance of legal certainty and stability in tax policy for foreign investors. It concluded that the transfer does not constitute an extinguishment of control over Indian assets, and Section 9 of the Indian tax law does not apply to this transaction. The Bombay High Court's decision was overturned.