The Approving Panel held that my client's arrangement is NOT an impermissible avoidance arrangement, but the Assessing Officer has taxed the same transaction under another section anyway. Can he do that?
The Mumbai Tribunal did not decide the wide question, but it held that the Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to the findings returned by the Approving Panel on the very arrangement referred to it. It then dismissed the Revenue's appeal on the narrower ground that a company buying back its own shares, which must then be extinguished, does not 'receive' property within section 56(2)(x) at all.
Decided by the ITAT (Amit Shukla, Judicial Member and Arun Khodpia, Accountant Member) on 2026-08-31, reported as ITA No.2503/Mum/2026 (Assessment Year 2022-23), Income Tax Appellate Tribunal, 'F' Bench, Mumbai; heard 3 August 2026, pronounced 31 August 2026. It bears on section 144BA, section 96, section 100, section 56(2)(x), section 56(2)(viia), section 115QA, section 153, section 36(1)(iii), section 36(1)(vii), section 36(2)(i), section Rule 11UA of the Income Tax Act 1961, in Assessment & Scrutiny, Deductions & Disallowances and How Tax Law Is Read matters.
This is one of the very few orders in which a GAAR reference has actually run its full course — reference under section 144BA, an Approving Panel direction, and then an assessment — and it is the first the library carries that addresses what a favourable Panel direction is worth. Three things emerge. First, the Panel's factual findings survive the Panel: the Tribunal treated them as conclusively establishing the factual and commercial substratum of the arrangement, binding the Assessing Officer who was giving effect to the statutory process. Second, the Revenue's contrary argument, built on section 100 — that a finding of no impermissible avoidance arrangement is confined to Chapter X-A and confers no immunity from an independent charging or deeming provision — was recorded but not decided; the Tribunal expressly found it unnecessary to pronounce on the assessee's wider proposition that rejection of GAAR excludes every other anti-abuse provision, and proceeded on the Revenue's own premise. So the question whether a favourable Panel direction blocks another provision remains open. Third, the order contains a point that will recur: before the Commissioner (Appeals) the assessee had argued that a section 144BA reference made on 30 March 2024, immediately before the ordinary section 153 limitation expired, was made to obtain the statutory extension of time; the Commissioner (Appeals) rejected it on the ground that section 144BA stipulates no minimum antecedent period and the section 153 extension operates by force of statute regardless of the Panel's eventual conclusion, and the Tribunal, there being no cross-objection, expressly refrained from expressing any opinion. That leaves the point live for a future case.
Binding on the AO and CIT(A) within the Tribunal's jurisdiction. Persuasive elsewhere.
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The assessee stored and handled liquefied gases. Under a Facility Agreement dated 4 November 1999 with Indo Gulf Corporation Ltd it built and operated an ammonia storage and handling facility inside IGCL's Gujarat premises, power being supplied by IGCL. Gujarat Electricity Board policy on captive power required the producer to hold a minimum equity stake in the recipient, so IGCL was allotted 7,80,000 equity shares of Rs 10 at a premium of Rs 30, an issue price of Rs 40 per share. It was contemplated from the outset that IGCL would claim no dividend or capital appreciation and that on cessation of the Facility Agreement the shares would be returned or bought back at the same Rs 40, the holding being linked to an interest-free deposit of Rs 3 crore placed by the assessee with IGCL. IGCL's undertaking merged into Hindalco Industries Ltd with effect from 1 April 2002. The Facility Agreement was renewed until 31 January 2020; Hindalco shut its DAP plant in July 2020 and a Settlement Agreement of 2 November 2021 provided consideration of Rs 33 crore for transfer of the facility and settlement of the contractual arrangements, Hindalco asking the assessee to complete the buy-back at Rs 40 per share. A rights issue in which Hindalco did not participate immediately preceded the buy-back, and the shares were extinguished on 7 March 2022. In assessment the Assessing Officer took a prima facie view that the arrangement might be an impermissible avoidance arrangement, made a reference under section 144BA on 30 March 2024, and the Approving Panel by directions dated 30 January 2025 held that it did not constitute an impermissible avoidance arrangement within section 96, finding the 26 per cent participation to be a regulatory formality rather than an investment and the return of the shares at the original price unremarkable. Notwithstanding that, the Assessing Officer taxed the difference between a fair market value of Rs 595.49 per share and the buy-back price of Rs 40, adding Rs 43,32,82,200 under section 56(2)(x), and also disallowed Rs 43,34,444 under section 36(1)(iii) and Rs 12,60,17,125 of loans written off. The Commissioner (Appeals) deleted all three additions and the Revenue appealed.
The Revenue's appeal was dismissed in its entirety (paragraph 40). On the GAAR aspect, the Tribunal held that the Approving Panel's findings conclusively establish the factual and commercial substratum of the arrangement examined by it, and that the Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to those findings (paragraph 17). It found it unnecessary to decide the wider proposition that rejection of GAAR by the Approving Panel excludes every other anti-abuse or substantive provision, and proceeded instead on the Revenue's own premise that section 56(2)(x) operates independently of Chapter X-A, holding that even so the Revenue had to establish the ingredients of section 56(2)(x) independently (paragraph 18). Those ingredients failed: a company buying back its own shares, which are then mandatorily extinguished under section 68(7) of the Companies Act 2013, does not receive 'property' of the character contemplated by section 56(2)(x) (paragraphs 19 to 24 and 39).
The Tribunal began from the peculiar factual setting — a 26 per cent holding created to satisfy a Gujarat Electricity Board captive-power requirement, with the exit price fixed almost two decades before section 56(2)(x) was enacted — and observed that this setting had not merely been asserted by the assessee but had been scrutinised under the statutory GAAR mechanism and examined by the Approving Panel (paragraph 16). It set out the Panel's findings and drew the consequence that they conclusively establish the arrangement's factual and commercial substratum for the purposes examined, so that the officer giving effect to the section 144BA process could not adopt an opposite factual premise (paragraph 17). It then recorded the Revenue's section 100 argument and deliberately left it undecided, holding that even on the Revenue's premise the statutory ingredients of section 56(2)(x) had to be independently satisfied and that the Panel's findings remained relevant to the factual and commercial character of the arrangement (paragraph 18). On the section 56(2)(x) question the Tribunal reasoned that inclusion of shares within 'property' does not conclude the enquiry, because the provision requires receipt of property by the recipient, and a company buying back its own shares acquires no investment in itself but reduces its share capital (paragraph 19); that section 68(7) of the Companies Act 2013 makes extinguishment an integral statutory consequence rather than a later discretionary act, so receipt and extinguishment cannot be severed to postulate an interstitial moment of property (paragraph 20); that the reasoning in Vora Financial Services (P.) Ltd. v. ACIT under section 56(2)(viia) is consistent with this, and the Revenue's distinction based on the move to section 56(2)(x) no longer carries weight after the Delhi High Court's decision in Principal Commissioner of Income-tax v. Globe Capital Market Ltd. dated 7 April 2026, which was itself concerned with section 56(2)(x) and a buy-back below Rule 11UA value (paragraphs 21 and 22); and that once the jurisdictional ingredient failed, the fair market value controversy and the wider contention that section 115QA is an exclusive code both became academic (paragraph 23).
The Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to the findings returned by the Panel on the very arrangement referred to it.
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Handle my notice → Ask a CA on WhatsAppThe Mumbai Tribunal did not decide the wide question, but it held that the Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to the findings returned by the Approving Panel on the very arrangement referred to it. It then dismissed the Revenue's appeal on the narrower ground that a company buying back its own shares, which must then be extinguished, does not 'receive' property within section 56(2)(x) at all. This was decided by the ITAT (Amit Shukla, Judicial Member and Arun Khodpia, Accountant Member) and bears on section 144BA, section 96, section 100, section 56(2)(x), section 56(2)(viia), section 115QA, section 153, section 36(1)(iii), section 36(1)(vii), section 36(2)(i), section Rule 11UA of the Income Tax Act 1961. It is reported as ITA No.2503/Mum/2026 (Assessment Year 2022-23), Income Tax Appellate Tribunal, 'F' Bench, Mumbai; heard 3 August 2026, pronounced 31 August 2026. This is one of the very few orders in which a GAAR reference has actually run its full course — reference under section 144BA, an Approving Panel direction, and then an assessment — and it is the first the library carries that addresses what a favourable Panel direction is worth. Three things emerge. First, the Panel's factual findings survive the Panel: the Tribunal treated them as conclusively establishing the factual and commercial substratum of the arrangement, binding the Assessing Officer who was giving effect to the statutory process. Second, the Revenue's contrary argument, built on section 100 — that a finding of no impermissible avoidance arrangement is confined to Chapter X-A and confers no immunity from an independent charging or deeming provision — was recorded but not decided; the Tribunal expressly found it unnecessary to pronounce on the assessee's wider proposition that rejection of GAAR excludes every other anti-abuse provision, and proceeded on the Revenue's own premise. So the question whether a favourable Panel direction blocks another provision remains open. Third, the order contains a point that will recur: before the Commissioner (Appeals) the assessee had argued that a section 144BA reference made on 30 March 2024, immediately before the ordinary section 153 limitation expired, was made to obtain the statutory extension of time; the Commissioner (Appeals) rejected it on the ground that section 144BA stipulates no minimum antecedent period and the section 153 extension operates by force of statute regardless of the Panel's eventual conclusion, and the Tribunal, there being no cross-objection, expressly refrained from expressing any opinion. That leaves the point live for a future case. If it applies to you, the first step is this: If the Approving Panel has found in the assessee's favour, extract its factual findings and put them at the front of the reply to any subsequent addition on the same transaction; the Tribunal held the Assessing Officer could not proceed on a factual premise diametrically opposed to them.
The assessee stored and handled liquefied gases. Under a Facility Agreement dated 4 November 1999 with Indo Gulf Corporation Ltd it built and operated an ammonia storage and handling facility inside IGCL's Gujarat premises, power being supplied by IGCL. Gujarat Electricity Board policy on captive power required the producer to hold a minimum equity stake in the recipient, so IGCL was allotted 7,80,000 equity shares of Rs 10 at a premium of Rs 30, an issue price of Rs 40 per share. It was contemplated from the outset that IGCL would claim no dividend or capital appreciation and that on cessation of the Facility Agreement the shares would be returned or bought back at the same Rs 40, the holding being linked to an interest-free deposit of Rs 3 crore placed by the assessee with IGCL. IGCL's undertaking merged into Hindalco Industries Ltd with effect from 1 April 2002. The Facility Agreement was renewed until 31 January 2020; Hindalco shut its DAP plant in July 2020 and a Settlement Agreement of 2 November 2021 provided consideration of Rs 33 crore for transfer of the facility and settlement of the contractual arrangements, Hindalco asking the assessee to complete the buy-back at Rs 40 per share. A rights issue in which Hindalco did not participate immediately preceded the buy-back, and the shares were extinguished on 7 March 2022. In assessment the Assessing Officer took a prima facie view that the arrangement might be an impermissible avoidance arrangement, made a reference under section 144BA on 30 March 2024, and the Approving Panel by directions dated 30 January 2025 held that it did not constitute an impermissible avoidance arrangement within section 96, finding the 26 per cent participation to be a regulatory formality rather than an investment and the return of the shares at the original price unremarkable. Notwithstanding that, the Assessing Officer taxed the difference between a fair market value of Rs 595.49 per share and the buy-back price of Rs 40, adding Rs 43,32,82,200 under section 56(2)(x), and also disallowed Rs 43,34,444 under section 36(1)(iii) and Rs 12,60,17,125 of loans written off. The Commissioner (Appeals) deleted all three additions and the Revenue appealed. The matter was decided on 2026-08-31 by the ITAT (Amit Shukla, Judicial Member and Arun Khodpia, Accountant Member). On those facts the ITAT held as follows. The Revenue's appeal was dismissed in its entirety (paragraph 40). On the GAAR aspect, the Tribunal held that the Approving Panel's findings conclusively establish the factual and commercial substratum of the arrangement examined by it, and that the Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to those findings (paragraph 17). It found it unnecessary to decide the wider proposition that rejection of GAAR by the Approving Panel excludes every other anti-abuse or substantive provision, and proceeded instead on the Revenue's own premise that section 56(2)(x) operates independently of Chapter X-A, holding that even so the Revenue had to establish the ingredients of section 56(2)(x) independently (paragraph 18). Those ingredients failed: a company buying back its own shares, which are then mandatorily extinguished under section 68(7) of the Companies Act 2013, does not receive 'property' of the character contemplated by section 56(2)(x) (paragraphs 19 to 24 and 39).
The Tribunal began from the peculiar factual setting — a 26 per cent holding created to satisfy a Gujarat Electricity Board captive-power requirement, with the exit price fixed almost two decades before section 56(2)(x) was enacted — and observed that this setting had not merely been asserted by the assessee but had been scrutinised under the statutory GAAR mechanism and examined by the Approving Panel (paragraph 16). It set out the Panel's findings and drew the consequence that they conclusively establish the arrangement's factual and commercial substratum for the purposes examined, so that the officer giving effect to the section 144BA process could not adopt an opposite factual premise (paragraph 17). It then recorded the Revenue's section 100 argument and deliberately left it undecided, holding that even on the Revenue's premise the statutory ingredients of section 56(2)(x) had to be independently satisfied and that the Panel's findings remained relevant to the factual and commercial character of the arrangement (paragraph 18). On the section 56(2)(x) question the Tribunal reasoned that inclusion of shares within 'property' does not conclude the enquiry, because the provision requires receipt of property by the recipient, and a company buying back its own shares acquires no investment in itself but reduces its share capital (paragraph 19); that section 68(7) of the Companies Act 2013 makes extinguishment an integral statutory consequence rather than a later discretionary act, so receipt and extinguishment cannot be severed to postulate an interstitial moment of property (paragraph 20); that the reasoning in Vora Financial Services (P.) Ltd. v. ACIT under section 56(2)(viia) is consistent with this, and the Revenue's distinction based on the move to section 56(2)(x) no longer carries weight after the Delhi High Court's decision in Principal Commissioner of Income-tax v. Globe Capital Market Ltd. dated 7 April 2026, which was itself concerned with section 56(2)(x) and a buy-back below Rule 11UA value (paragraphs 21 and 22); and that once the jurisdictional ingredient failed, the fair market value controversy and the wider contention that section 115QA is an exclusive code both became academic (paragraph 23). In the words reproduced by the source cited on this page: "The Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to the findings returned by the Panel on the very arrangement referred to it." The decision followed or applied Vora Financial Services (P.) Ltd. v. ACIT, [2018] 194 TTJ 746 (Mum.), ITA No.532/Mum/2018, order dated 29.06.2018 — reasoning applied; Principal Commissioner of Income-tax v. Globe Capital Market Ltd., judgment dated 07.04.2026 (Delhi High Court) — followed on section 56(2)(x) and buy-back; Principal Commissioner of Income-tax v. Khyati Realtors (P.) Ltd. (2022) 447 ITR 167 (SC) — distinguished on facts.
It was decided by the ITAT on 2026-08-31 and is reported as ITA No.2503/Mum/2026 (Assessment Year 2022-23), Income Tax Appellate Tribunal, 'F' Bench, Mumbai; heard 3 August 2026, pronounced 31 August 2026. Binding on the AO and CIT(A) within the Tribunal's jurisdiction. Persuasive elsewhere. A Tribunal decision binds the assessing officer and the Commissioner (Appeals) within that Tribunal's jurisdiction, and is persuasive before other benches. It is not binding on a High Court, and a contrary co-ordinate bench decision will be argued against you, so check whether the point has been taken the other way before you build a reply around it. On section 144BA, section 96, section 100, section 56(2)(x), section 56(2)(viia), section 115QA, section 153, section 36(1)(iii), section 36(1)(vii), section 36(2)(i), section Rule 11UA, the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It helps the taxpayer. The Revenue's appeal was dismissed in its entirety (paragraph 40). On the GAAR aspect, the Tribunal held that the Approving Panel's findings conclusively establish the factual and commercial substratum of the arrangement examined by it, and that the Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to those findings (paragraph 17). It found it unnecessary to decide the wider proposition that rejection of GAAR by the Approving Panel excludes every other anti-abuse or substantive provision, and proceeded instead on the Revenue's own premise that section 56(2)(x) operates independently of Chapter X-A, holding that even so the Revenue had to establish the ingredients of section 56(2)(x) independently (paragraph 18). Those ingredients failed: a company buying back its own shares, which are then mandatorily extinguished under section 68(7) of the Companies Act 2013, does not receive 'property' of the character contemplated by section 56(2)(x) (paragraphs 19 to 24 and 39). It arises in Assessment & Scrutiny, Deductions & Disallowances and How Tax Law Is Read matters, on section 144BA, section 96, section 100, section 56(2)(x), section 56(2)(viia), section 115QA, section 153, section 36(1)(iii), section 36(1)(vii), section 36(2)(i), section Rule 11UA of the Income Tax Act 1961, and was decided by Amit Shukla, Judicial Member and Arun Khodpia, Accountant Member. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. Do not over-claim: this order does not hold that a favourable Panel direction excludes every other provision. Argue the other provision's own statutory ingredients as the primary case and keep the Panel findings as the factual foundation. Where the Revenue relies on section 100 to say GAAR and another provision occupy distinct fields, note that the Tribunal assumed that premise in the Revenue's favour and still dismissed the appeal, so the argument is not by itself an answer. If a section 144BA reference was made on the eve of the section 153 limitation date, preserve the point by a cross-objection or an additional ground — the Tribunal declined to decide it here only because no cross-objection was before it. On the buy-back point itself, run section 68(7) of the Companies Act 2013: extinguishment is an integral statutory consequence of the buy-back, so receipt and extinguishment cannot be severed to postulate property in the company's hands. Keep contemporaneous documents proving the commercial or regulatory genesis of a shareholding; here the 26 per cent holding and the fixed exit price of Rs 40 per share were documented in 2000-2001 and were what persuaded both the Approving Panel and the Tribunal.
Searched for later treatment; none was found. That is not the same as a source affirming it. No later decision has been found citing this order, and no judicial treatment of it has been established either in the Tribunal or above. A later order in the same assessee's own file — Sanjana Cryogenic Storages Ltd v DCIT, ITAT Mumbai, 4 September 2026 — does not refer to it at all; it concerns depreciation on Iron Ore Rights for assessment year 2019-20 and records that the same depreciation question is pending before the Bombay High Court for earlier years. That pendency does not touch the approving-panel holding recorded here. No appeal under s.260A, and so no High Court reversal, has been traced, and no later Bench has been found taking the opposite view. Read the silence for what it is. This is an order of August 2026, so the absence of citation reflects its age rather than any settled acceptance of it. A practitioner may cite it as the only direct authority known here on what a favourable Approving Panel direction is worth, but should not present it as settled law, and should expect the Revenue to press the s.100 argument that the Tribunal expressly declined to decide — that a finding of no impermissible avoidance arrangement is confined to Chapter X-A and confers no immunity from an independent charging or deeming provision. The narrower ground on which the appeal was actually dismissed, that a company buying back its own shares which are then mandatorily extinguished under s.68(7) of the Companies Act 2013 does not receive 'property' within s.56(2)(x), is the safer of the two propositions to run, and it rests on the Delhi High Court decision in Globe Capital Market Ltd as well as on the earlier reasoning in Vora Financial Services under s.56(2)(viia). What would change the position is a High Court ruling on the binding quality of Approving Panel findings, or a contrary Bench decision on whether a buy- back can be a receipt of property at all. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
The order was pronounced on 31 August 2026 and runs to 40 numbered paragraphs, ending with the disposal at paragraph 40 and the signature block. The stretch that matters is paragraphs 16 to 24: paragraph 16 sets out the factual setting, paragraph 17 holds that the Approving Panel's findings conclusively establish the factual and commercial substratum so that the officer giving effect to the s.144BA process cannot adopt an opposite factual premise, paragraph 18 records the Revenue's s.100 argument and expressly leaves it undecided, and paragraphs 19 to 24 work out the s.56(2)(x) point, with paragraph 39 carrying it into the disposal. Paragraph 21 cites a Delhi High Court judgment in Principal Commissioner of Income-tax v. Globe Capital Market Ltd dated 7 April 2026 on s.56(2)(x) and buy-back. That judgment has not been examined for this entry and nothing is stated here about what it holds, beyond the fact that the Tribunal relied on it; anyone running the point should read it rather than take it at second hand. Scope: this entry is carried for the GAAR aspect. The s.36(1)(iii) and s.36(1)(vii) holdings at paragraphs 25 to 37 are not described here. The dates matter when the sequence is argued: the s.144BA reference was made on 30 March 2024, the Approving Panel's directions are dated 30 January 2025, and the assessment order 30 March 2025. Three questions are left open by the order and a practitioner should not read them as decided. Whether a favourable Approving Panel direction bars the Revenue from invoking an independent charging or deeming provision was argued on s.100 and deliberately not answered; the Tribunal proceeded on the Revenue's own premise that s.56(2)(x) operates independently of Chapter X-A and held that even so the ingredients failed. Whether the fair market value of Rs 595.49 per share, worked out against a buy-back price of Rs 40, was correctly computed under Rule 11UA became academic once the jurisdictional ingredient failed. And whether s.115QA is an exclusive code for buy-back taxation was raised and likewise left academic. One further point was raised below and expressly not touched by the Tribunal. Before the Commissioner (Appeals) the assessee had argued that a s.144BA reference made on 30 March 2024, immediately before the ordinary s.153 limitation expired, was made to obtain the statutory extension of time. The Commissioner (Appeals) rejected that on the footing that s.144BA stipulates no minimum antecedent period and that the s.153 extension operates by force of statute whatever the Panel eventually concludes; there being no cross-objection, the Tribunal expressly refrained from expressing any opinion, so the argument remains available in a later case. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
The Revenue's appeal was dismissed in its entirety (paragraph 40). On the GAAR aspect, the Tribunal held that the Approving Panel's findings conclusively establish the factual and commercial substratum of the arrangement examined by it, and that the Assessing Officer could not, while giving effect to the statutory process under section 144BA, proceed on a factual premise diametrically opposed to those findings (paragraph 17). It found it unnecessary to decide the wider proposition that rejection of GAAR by the Approving Panel excludes every other anti-abuse or substantive provision, and proceeded instead on the Revenue's own premise that section 56(2)(x) operates independently of Chapter X-A, holding that even so the Revenue had to establish the ingredients of section 56(2)(x) independently (paragraph 18). Those ingredients failed: a company buying back its own shares, which are then mandatorily extinguished under section 68(7) of the Companies Act 2013, does not receive 'property' of the character contemplated by section 56(2)(x) (paragraphs 19 to 24 and 39).
TaxSphere, “DCIT, Central Circle 8(3), Mumbai v Sanjana Cryogenic Storages Ltd”, https://taxnotice.vittsphere.com/caselaw/case/dcit-v-sanjana-cryogenic-storages-approving-panel-findings-binding/ (validity last checked 2026-09-08)
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