On 20 January 2012, a three-judge bench of the Supreme Court — S.H. Kapadia C.J., K.S. Radhakrishnan J. and Swatanter Kumar J. — unanimously held that the transfer of a single share in a Cayman Islands holding company (CGP) between two non-residents did not give rise to capital gains taxable in India under Section 9(1)(i) of the Income-tax Act, 1961, even though the share's value was rooted in the Hutch–Vodafone Indian telecom chain; the look-at test was adopted, and the Revenue's USD 2.2 billion demand was quashed. Parliament responded with the Finance Act 2012 retrospective amendment to Section 9(1)(i); Vodafone then commenced a treaty arbitration under the India–Netherlands BIT and prevailed; the Taxation Laws (Amendment) Act 2021 ultimately rolled back the retrospective amendment. A digest of the judgment, its statutory architecture, and the doctrinal arc that has followed.