crores.
(b) On 10.05.2013, Chapter XIIDA consisting of Sections 115QA,
115QB and 115QC was inserted in the Income Tax Act, 1961 (hereinafter
referred ... Finance Act, 2013 which came into effect
from 01.06.2013. Section 115QA as it stood prior to the amendment which
came into effect
buybackâ under Section 77-A CA
for the purposes of Section 115QA of the Act, as it stood at the relevant
time ... Assessment Officer's (AO) determination that the levy under
Section 115QA of the Finance Act, 2013 [(as existing prior to
its amendment) hereinafter
back the shares because of new provision introduced vide Section
115QA of the IT Act, viz., Buyback Distribution Tax ["BBDT"] from 01.06.2013
imposing ... remaining amount under Section 115 QA of the IT Act. Section
115QA was inserted in the Act and came to effect from 01.06.2013 and this
appellate remedy available, in case any determination is made
under Section 115QA of the Act that the Company is liable to pay
"additional income ... would be no appellate
remedy in case of any determination under Section 115QA. The issues may
arise not just confined to the question whether
huge sum, the present demand cannot be made. The
explanation to Section 115QA of the Act was amended with effect from
01.06.2016. Post amendment ... Hence, the demand of
tax under Section 115QA of the Act retrospectively is not permissible in law.
12. It is next contended that admittedly
prima facie of the view that the
transactions defined in Section 115QA were initially confined only to
those covered by Section 77A of the Companies ... hearing touching upon
the aspects whether the appellant is liable under Section 115QA of the
Act or whether the transaction of buy back of shares
prima
facie of the view that the transactions defined in Section 115QA
were initially confined only to those covered by Section 77A of
the Companies ... hearing
touching upon the aspects whether the appellant is liable
under Section 115QA of the Act or whether the
transaction of buy back of shares
prima facie of the view that the
transactions defined in Section 115QA were initially confined only to
those covered by Section 77A of the Companies ... hearing touching upon
the aspects whether the appellant is liable under Section 115QA of the
Act or whether the transaction of buy back of shares
prima facie of the view that the
transactions defined in Section 115QA were initially confined only to
those covered by Section 77A of the Companies ... hearing touching upon
the aspects whether the appellant is liable under Section 115QA of the
Act or whether the transaction of buy back of shares
prima facie of the view that the
transactions defined in Section 115QA were initially confined only to
those covered by Section 77A of the Companies ... hearing touching upon
the aspects whether the appellant is liable under Section 115QA of the
Act or whether the transaction of buy back of shares
