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    <title>2026 (7) TMI 879 - ITAT DELHI</title>
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    <description>Court-approved capital reduction through direct cancellation of shares is distinct from a buy-back and is not taxable under the buy-back tax regime; treating it as both capital reduction and buy-back would create impermissible double taxation. Interest on borrowings used in commercially expedient capital restructuring was characterised as revenue expenditure deductible for business purposes. Interest on compulsorily convertible debentures remained deductible because the instruments retained their debt character until conversion and the foreign subscription was adequately substantiated. Property management fees and customer advances were supported by contractual and documentary evidence, so the related disallowances lacked an evidentiary basis.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794993</link>
      <description>Court-approved capital reduction through direct cancellation of shares is distinct from a buy-back and is not taxable under the buy-back tax regime; treating it as both capital reduction and buy-back would create impermissible double taxation. Interest on borrowings used in commercially expedient capital restructuring was characterised as revenue expenditure deductible for business purposes. Interest on compulsorily convertible debentures remained deductible because the instruments retained their debt character until conversion and the foreign subscription was adequately substantiated. Property management fees and customer advances were supported by contractual and documentary evidence, so the related disallowances lacked an evidentiary basis.</description>
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