International arbitration is the flavour of the month with foreign firms in India finding themselves at a dead end with either the executive or the judiciary. In his March 16 Budget speech, finance minister Pranab Mukherjee had proposed a retrospective amendment to the Income Tax Act, 1961, to cover overseas mergers and acquisitions involving assets in India. This came as a googly to the British multinational Vodafone, which had been told by the Supreme Court in January that it was not liable to pay tax on its $11.2 billion acquisition of Hutchison’s stake in Hutchison-Essar in 2007.