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• The assessee tried to argue that the payment was made as consideration for purchase of own shares and it is quid pro quo and that it is not a voluntary distribution to qualify dividend. This argument of the assessee is not acceptable: First of all, it is not the transaction of general purchase of shares; it is purchase of own shares; the shares purchased are not available for resale as in any ordinary purchase, as such purchased shares gets extinguished automatically. 'Reduction of capital' happens as part of the transaction. It is deemed to be dividend u/s 2(22)(d). Meaning has to be taken specifically from section 2(22ld) when there is capital reduction. 'Purchase of own shares' from shareholders involved 'capital reduction' accompanied by payment from accumulated profits to the shareholders and hence, section 2(22)(d) applies. In such cases, the payment cannot be considered as consideration for purchase, but it has to be considered as 'dividend' by operation of law as provided in section 2(22)(d). • Assessee again tried to argue that only a distribution paripassu (in equal proportion) amongst shareholders can be considered as 'distribution' for the purposes of sections 2(22)(a) or 2(22)(d). This argument is also not acceptable. Assessee extrapolates words into the Act, which is not permissible. Nowhere in section 2(22), there is such stipulation. Assessee cannot go by any general meaning for the dividends u/ s 2(22). Legal meaning as provided in the provisions of section 2(22) can only be looked into. In the impugned transaction of the assessee, there is capital reduction, which is indisputable; and that accompanied payment from accumulated profits to the shareholders; and the impugned transaction is not buy-back u/s 77A. Then, as per the legal meaning of those relevant provisions, it is dividend u/s 2(22)(d)/(a).