Composite contract for installation & commissioning cannot be split to exempt profits from offshore supply of goods

In Vodafone International Holdings BV Netherlands vs. Union of India and another (345 ITR 1 (SC).  a three judge bench of the Supreme Court has laid down that what is needed is to consider the transaction in its entirety and to look at the transaction as a whole. The Supreme Court has advocated that a transaction must be looked at and not looked through. The learned Chief Justice has held “it is the task of the Revenue / Court to ascertain the legal nature of the transaction and while doing so, it has to look at the transaction as a whole and not adopt a dissecting approach”. This injunct...