This article examines the decision of the Delhi High Court to apply the doctrine of mobilia sequuntur personam to restrict India’s jurisdiction to tax gains derived by the Foster’s brewing group on the sale of intellectual property used in India. The authors address the reasoning behind the decision of the Authority for Advance Rulings in favour of the Indian tax authority and its subsequent rejection by the High Court. They also discuss how the High Court decision could have been enhanced by incorporating a more comprehensive discussion of overseas precedents.