https://www.taxtmi.com/caselaws?id=296090 AAR Mumbai ruled that share buy-back transactions are taxable under section 46A, rejecting exemption claims under section 47(iv). The authority held that special provision 46A prevails over general provisions, as shares cease to exist post buy-back making other sections redundant. For non-resident companies, MAT liability under section 115JB applies only to profits attributable to permanent establishment. The resident company must withhold taxes under section 195 on buy-back consideration paid to non-residents. en-us Thu, 03 Oct 2019 00:00:00 +0530 Thu, 12 Jun 2025 17:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296090 AAR Mumbai ruled that share buy-back transactions are taxable under section 46A, rejecting exemption claims under section 47(iv). The authority held that special provision 46A prevails over general provisions, as shares cease to exist post buy-back making other sections redundant. For non-resident companies, MAT liability under section 115JB applies only to profits attributable to permanent establishment. The resident company must withhold taxes under section 195 on buy-back consideration paid to non-residents. Case-Laws Income Tax Thu, 03 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296090