Redemption of preference shares is "transfer" even if both issuer and subscriber companies are under same management as they are both distinct juridical entities

Redemption of preference shares constitutes a transfer even where issuer and subscriber share management, due to separate juridical personality. Redemption of preference shares constitutes a transfer for legal and tax purposes even when issuer and subscriber are under the same management, because they are distinct juridical entities; common management does not negate separate corporate personality and the redemption therefore triggers transfer characterization.