The infamous retrospective tax battle over Rs 20,000 crore of alleged dues may have reached finality with Vodafone International Holdings recording a major victory against the Indian Tax department, in Arbitration.

The Permanent Court of Arbitration in Hague has held that the conduct of the Indian authorities was in breach of “fair and equitable” treatment assured under the Bilateral Investment Treaty (BIT), signed between Netherlands and India.

The tax dispute began with the British telecom major's entry into the Indian market in 2007. Since then the case has seen various rounds of litigation, retrospective amendments to the Income Tax Act and international arbitrations. The arbitral tribunal, protecting Vodafone, terming the actions of Indian authorities as a breach of bilateral investment treaty, have brought the issue to a close.

Will the issue rest? Will the Indian government accept this decision, in toto?

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