Whether reduction in share capital amounts to a transfer if consideration is paid

M/s. Carestream Health Inc. vs. DCIT (ITAT Mumbai) Mumbai ITAT Ruling: Whether reduction in share capital amounts to a transfer and thereby gives rise to capital gains, if consideration is paid for such reduction? Facts of the case: – Carestream Health Inc. (taxpayer or the assessee) is a tax resident and company incorporated in the United States (USA). Carestream Health Pvt. Ltd. (CHIPL) is a wholly owned subsidiary of the taxpayer, resident in India. – In assessment year (AY) 2011-12, a capital reduction scheme, duly approved by the High Court (HC), was undertaken by CHIPL, where...