Ruling on Exemption under Section 47(iv) of the Income Tax Act (1961) Regarding a Share Buy-Back from a Parent Company by the Parent’s Wholly Owned Subsidiary

This article analyses the recent ruling of the Authority for Advance Rulings that denied the exemption available under section 47(iv) of the Indian Income Tax Act (1961) on the buy-back of the shares of a wholly owned subsidiary held by the parent company by the wholly owned subsidiary itself.