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    <title>2026 (4) TMI 978 - DELHI HIGH COURT</title>
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    <description>A statutory buy-back of a company&#039;s own shares under the Companies Act, 2013 is a reduction of share capital that ends in extinguishment of the bought-back shares. On that corporate law characterisation, section 56(2)(x) of the Income-tax Act, 1961 and Rule 11UA do not apply, because the provision presupposes acquisition of property at less than fair market value and that premise fails where the shares cease to exist on completion. The Revenue&#039;s broader reading was treated as inconsistent with the nature of a buy-back, and the addition made on that basis was unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=789909</link>
      <description>A statutory buy-back of a company&#039;s own shares under the Companies Act, 2013 is a reduction of share capital that ends in extinguishment of the bought-back shares. On that corporate law characterisation, section 56(2)(x) of the Income-tax Act, 1961 and Rule 11UA do not apply, because the provision presupposes acquisition of property at less than fair market value and that premise fails where the shares cease to exist on completion. The Revenue&#039;s broader reading was treated as inconsistent with the nature of a buy-back, and the addition made on that basis was unsustainable.</description>
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