The firm is India's largest overseas corporate investor, but has been caught up in a five-year tax battle.
The issue relates to Vodafone's 2007 takeover of Hong Kong-based Hutchison Whampoa's Indian mobile unit.
Vodafone said a move to retrospectively tax overseas mergers would go against court decisions and legal protections given to investors.
As a result it said it had served the Indian government with a "notice of dispute" in a first step toward international arbitration.
And it argued that the new Indian tax legislation was an attempt to bypass a ruling by the country's Supreme Court in January that Vodafone was not liable for taxes and penalties of up to $4.4bn (£2.8bn)
To retroactively tax overseas mergers would "countermand" the court verdict and "violates international legal protections granted to Vodafone and other international investors in India", Vodafone added in a statement.
The notice was served by Vodafone's Dutch subsidiary.
Vodafone has threatened to take India to international arbitration over planned retrospective tax legislation.