Buyback Gains Taxable Under Section 46A as Section 47(iv) Conditions Not Met: ITAT Bangalore

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 ITAT Bangalore W...