The appeal in this case was made against the judgment of the Bombay High Court. The High Court had ruled in favor of the Indian tax authorities, holding that Vodafone ... International Holdings B.V. was liable to pay capital gains tax on its acquisition of shares in computer graphics package Investments (Holdings) Ltd., a Cayman Islands company, which indirectly held assets in India. The dispute centered on whether the transfer of shares in an offshore company that indirectly held interests in an Indian company should be subject to Indian capital gains tax.