M/S FIDELITY BUSINESS SERVICES INDIA PVT LTD vs. ASSISTANT COMMISSIONER OF INCOME TAX
ITA/512/2017HC Karnataka23 Jul 2018
Bench: S.SUJATHA,VINEET KOTHARI
Section 2(22)(e)Section 254Section 260
transfer of the reserves and surplus to
the holding company by avoiding the
payment of tax and therefore it will be
treated as a colourable device. There are
two aspects in this transaction-
(i) It is a simple and plain transaction of
buy back of shares without having any
dispute of price then the same is beyond the
scope
