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It is now a settled position of law that interest under s. 201(1A) of the Act is mandatory and therefore, on this issue also, we find no reason to interfere in the order of the learned CIT(A).

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Section 45, 46A & 47(iv) of the Income Tax Act, 1961– Capital gains– Deemed Capital gain is chargeable under section 46A as in case of buy back of shares by a company, section 47(iv) was not applicable since parent company is not holding whole of the share Capital of the subsidiary company along with its nominees– Acciona Wind Energy P. Ltd. Vs. Deputy Commissioner of income tax [2020] 203 TTJ (Bangalore) 377

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