On Friday Vodafone Essar wanted cover from the Bombay High Court after the Income- tax department started action against the telecom operator telling it an ‘agent’ for tax collection for Hutchison.

I-T department and Vodafone have been protected in legal action since 2008 above Vodafone’s 2007 purchase of a majority stake in the company in that case known as Hutchison Essar for $11 billion.

In the Supreme Court a case is already being heard to charge if the Indian taxman has power over the transaction.

The most recent move by the tax department enlarges the significance of the legal challenge facing Vodafone, as it assigns final guilt on the UK-based company rather than reproving it of not withholding tax from Hutchison.

The legal responsibility on Vodafone may also increase if the courts sustain the view that it was acting as an agent of Hutchison, say people known with the case.

A Vodafone group spokesman said that the Tax Office’s actions are a curious development, not least because they overlook the forthcoming investigation at the SC on the jurisdiction problem.