Supreme Court: Share Capital Reduction in Subsidiary is a Transfer u/s 2(47) of Income Tax Act.

The SC held that the reduction in share capital of the subsidiary company and subsequent proportionate reduction in the shareholding of the assessee would be covered within the ambit of "sale, exchange or relinquishment of the asset" u/s 2(47) of the Income Tax Act, 1961. Relying on Anarkali Sarabhai case, it was observed that reduction of share capital or redemption of shares involves purchase of its own shares by the company and hence included within the meaning of transfer u/s 2(47). The matter was decided in favor of the assessee. .....

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