Lifting of Corporate Veil to tax sale of Foreign Company shares by one Non-Resident to another Non-Resident if Foreign Co holds shares in Indian Company

Keeping in mind the historical background, rather its origin, one feels that, neither Vodafone, being the first court case of its kind, nor any of the other Indian tax cases which have come to be widely discussed with reference to the Vodafone case, can be strictly regarded to have been considered by invoking the principle of – ‘lifting the corporate veil’ (in fact, the term often more appropriately used is – ‘piercing the corporate veil’). To put it differently, in most of these court cases of recent origin, the issue might be said to be rested on the controversy – whether or not the true nature of the given transaction(s) should be ascertained wholly and necessarily having regard to the actual / factual terms of the related contract agreement (s). Thus, the real ‘battle of wits’ is one of – Form vs Substance.
For an analytical study, and an appreciation of the above comment, the following material in public domain may be of help:
Lifting the corporate veil definition
Articles piercing the corporate veil
Fdcc quarterly piercing the corporate veil
Fdcc quarterly separate corporate personality piercing
Separate corporate personality articles