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Buyback Gains Taxable Under Section 46A as Section 47(iv) Conditions Not Met: ITAT Bangalore
Case Law Details
- Case Name
- Acciona Wind Energy Private Limited Vs DCIT (International Taxation) (ITAT Bangalore)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2014-15
- Courts
- All ITAT, ITAT Bangalore
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Acciona Wind Energy Private Limited Vs DCIT (International Taxation) (ITAT Bangalore)
Section 47(iv) Exemption Denied Since Parent Company Did Not Hold Entire Share Capital: ITAT; ITAT Bangalore Holds Buyback of Shares Covered by Section 46A, Not Section 45; Buyback Transaction Taxable as Deemed Capital Gains Due to Inapplicability of Section 47(iv); ITAT Rejects Claim That Minimum Two Shareholders Requirement Grants Section 47(iv) Relief; Capital Gains on Buyback Taxable Even Without Transfer Requirement Under Section 46A: ITAT; Interest Under Section 201(1A) Mandatory, Rules...
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