In this appeal before the Judicial Committee of the Privy Council, Sanjay successfully reversed the Supreme Court’s decision that management services provided by Shophold to its sister company, Shoprite, was made for ‘consideration’ under section 4(1)(b) of the Value Added Tax Act 1998. The Privy Council held that there was no consideration, and that VAT was therefore not payable. Sanjay was assisted by Jason Harel and Sandiram Poonisamy, of counsel.