Recasting 2007 Framework Agreement Not an Assignment of Option Rights; Distinguished from Vodafone Ruling Due to Section 2(47) Amendment.

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....TPA - Whether recasting of framework agreement in 2007 tantamount assignment of option rights held by the assessee under framework agreements of 2006 - Decided against the assessee - Decision in the matter of Vodafone India Holdings BV Vs. UOI [2012 (1) TMI 52 - SUPREME COURT OF INDIA] distinguished in view of subsequent amendment to Section 2(47) - AT....