The tax department has sought a review of a Supreme Court verdict dismissing a $2.2 billion tax demand on Vodafone Group Plc, a document seen by Reuters showed, while the British company remained confident that it was not liable for any tax.
Indian rules allow filing of a review plea on any Supreme Court judgment within 30 days of the verdict.
The Supreme Court ruled last month that the country's tax office had no jurisdiction to tax Vodafone's $11 billion deal in 2007 to buy Hutchison Whampoa's Indian mobile business, in a huge relief to the British group fighting a legal battle for five years.
Vodafone, the world's biggest mobile phone carrier by revenue, said in a statement the tax authority's review plea filed on Friday would be evaluated by the same judges, who it said had ruled "clearly and unambiguously" that no tax was due.
Vodafone, the largest overseas corporate investor in India, expanded into the Indian arena to balance out slowing growth in more mature European territories. Its unit in the country is the country's second-largest mobile carrier by revenue and third-largest by subscribers.
The tax case win last month was seen encouraging foreign investments into India, at a time when the country's image as an investment destination has taken a beating on slower economic growth and stalled policy reforms amid corruption scandals.
The verdict also cleared the way for a planned initial public offering of Vodafone's Indian unit.