Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
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Buy-back of a company's own shares under section 68 of the Companies Act is treated as a reduction of share capital, because the bought-back shares must be extinguished and destroyed. On that basis, the company does not acquire property at a price below fair market value for purposes of section 56(2)(x), and the deeming provision is inapplicable. The Court also noted that reliance on section 56(2)(viia) precedent was misplaced, but the appellate authorities had independently adopted the correct view. The deletion of the addition relating to buy-back of own shares was upheld and the Revenue's appeal failed.
Buy-back of a company's own shares under section 68 of the Companies Act is treated as a reduction of share capital, because the bought-back shares must be extinguished and destroyed. On that basis, the company does not acquire property at a price below fair market value for purposes of section 56(2)(x), and the deeming provision is inapplicable. The Court also noted that reliance on section 56(2)(viia) precedent was misplaced, but the appellate authorities had independently adopted the correct view. The deletion of the addition relating to buy-back of own shares was upheld and the Revenue's appeal failed.
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