LAWS(APH)-2013-2-99

SANOFI PASTEUR HOLDINGS SA Vs. DEPARTMENT OF REVENUE

Decided On February 15, 2013
Sanofi Pasteur Holdings Sa Appellant
V/S
Department Of Revenue Respondents

JUDGEMENT

(1.) The three writ petitions pertain to a tax dispute between the petitioners and the Indian Tax authorities (for short, 'the Revenue') in relation to the acquisition in August, 2009 by M/s. Sanofi Pasteur Holding SA, France (for short, 'Sanofi') of the entire share capital of M/s. ShanH SAS, France (for short, 'ShanH'), a Joint venture company, from its constituents M/s. Merieux Alliance, France (for short, 'MA') and M/s. Groupe Industrial Marcel Dassault (for short, 'GIMD'). As on the date of acquisition by Sanofi (of the entire share capital of ShanH), ShanH held about 80% of the shares in Shanta Biotechnics Ltd. Hyderabad (for short, 'SBL').

(2.) W.P. Nos. 3339 and 3358 of 2012:

(3.) A brief account of SBL, MA, GIMD and Sanofi: