https://www.taxtmi.com/highlights?id=98141 Buy-back of shares by an Indian subsidiary was treated as a corporate reorganisation because the transaction involved transfer of shares within the same corporate group and changed the form of the foreign shareholder's interest without altering its underlying ownership. Relying on the understanding of corporate restructuring reflected in professional guidance and the object of Article 13(5) of the India-Netherlands DTAA, the Tribunal held that the resulting gains fell within that treaty provision. The gains were therefore not taxable in India, and the assessee's appeal was allowed by majority. en-us Fri, 27 Mar 2026 08:52:56 +0530 Fri, 27 Mar 2026 08:52:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98141 Buy-back of shares by an Indian subsidiary was treated as a corporate reorganisation because the transaction involved transfer of shares within the same corporate group and changed the form of the foreign shareholder's interest without altering its underlying ownership. Relying on the understanding of corporate restructuring reflected in professional guidance and the object of Article 13(5) of the India-Netherlands DTAA, the Tribunal held that the resulting gains fell within that treaty provision. The gains were therefore not taxable in India, and the assessee's appeal was allowed by majority. Highlights Income Tax Fri, 27 Mar 2026 08:52:56 +0530 https://www.taxtmi.com/highlights?id=98141