Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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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