The income tax (I-T) department appears keen on challenging the Bombay High Court verdict on the Vodafone and Shell transfer pricing cases in the Supreme Court, “purely on the merits” of the case.
The judges had struck down I-T department’s orders in both the cases, upholding the companies’ pleas. Officials told Business Standard the Central Board of Direct Taxes (CBDT) was likely to recommend a Supreme Court petition in both the cases, also to get more clarity.

Source - http://www.business-standard.com