S. 2(22)(d) : Dividend-Any distribution to its share holders on the reduction of its share capital-Buy back of shares-Scheme of arrangement or compromise-There was a capital reduction and distribution out of accumulated profit of company to its shareholders, same would entail release of all or part of assets of a company on reduction of capital and would attract provisions of section 2(22)(d), and consequently, assessee was liable for payment of DDT under section 115-O. [S. 115O, 115QA, Companies Act 1956, S. 77, 77A 100 to104, 391, 292, 393]
Cognizant Technology Solutions India (P.) Ltd v. ACIT (2023) 108 ITR 492 / 154 taxmann.com 309 (Chennai)(Trib)