AAR held that on the facts of the case, the shares buy-back transaction is taxable under section 46A and exemption under section 46 (iv) is not applicable. As regards the minimum alternative tax liability under section 115JB, the Assessing Officer is required to compute the book profits of the supervisory permanent establishment and the minimum alternative tax liability would be restricted to the profit attributable to such supervisory permanent establishment for the relevant assessment year. The provisions of section 195 would be applicable and PQR India is liable to withhold taxes on the consideration payable for the buy back of shares.  (AAR No. 1195 of 2011 dt.3-10-2019)