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of <h1>ITAT Mumbai rules pre-June 2016 capital reduction not a 'buyback' u/s 115QA; emphasizes amendment timing.</h1> The Income Tax Appellate Tribunal (ITAT) Mumbai addressed the tax implications of capital reduction transactions, focusing on Section 115QA of the Income-tax Act, 1961. The case involved an appeal by the Assistant Commissioner of Income Tax regarding an assessment under Section 143(3). The Tribunal determined that the capital reduction transaction, completed before the June 1, 2016 amendment, did not qualify as a 'buyback' under the expanded definition of Section 115QA. The decision emphasized the importance of transaction dates in relation to legislative amendments and clarified that the broader post-amendment definition did not apply retroactively. The Tribunal upheld the legality of the transaction, dismissing claims of tax avoidance.
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