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"Happiness can be defined, in part at least, as the fruit of the desire and ability to sacrifice what we want now for what we want eventually" - Stephen Covey

Sunday, April 19, 2026

Newspaper Summary 180426

 The article titled "Spaces Where Art is Born" (featured on the front page) corresponds to the full feature on page 10 titled "The artists framed in their studios," written by Avantika Bhuyan. The piece explores a new book, Portrait of an Artist, conceptualized and shot by Rohit Chawla, which delves into the private workspaces of 68 modern and contemporary artists.

Overview of the Book

The publication features text by writer-curator Kishore Singh and essays by Ina Puri and Girish Shahane. It aims to provide an “honest record” of artists’ inner lives and creative processes, stripped of the "theatrical" manufacturing often found in fashion and advertising photography. Chawla shot the portraits in black and white over several years to maintain a sense of minimalism and candidness.

A Memorial Archive

Kiran Nadar, in her foreword, highlights the project's poignancy, as several featured masters—including Ram Kumar, Tyeb Mehta, Manjit Bawa, and Bhupen Khakhar—have passed away since the project began. The book preserves the "essential" ways they worked and thought in studios that are now silent. Chawla recalls the generosity of these modernists, such as Krishen Khanna reciting Chaucer at age 100.

Defining the Studio

The article questions what a studio truly is, noting that for some, like Claude Monet, it was the expansive outdoors. Kishore Singh describes a studio as both "a place of infinite freedom and a lifelong prison; dream and nightmare; paradise and hell".

Diverse Creative Spaces Highlighted

The book showcases the myriad forms these workspaces take:

  • Akbar Padamsee: Featured in a series of intimate frames, his studio is described as a "sanctuary" where his "spiritual innerscapes" were born.
  • Madhvi Parekh: Paints in her Delhi home outside her kitchen; an idli cooker is visible near canvases of fantastical worlds.
  • Arpita Singh: Her workspace in Nizamuddin East is partitioned from her home by a bookshelf filled with titles by authors like William Dalrymple.
  • Veer Munshi: His "studio in exile" in the National Capital Region serves as a space of healing, combining his Kashmiri heritage with interests in gardening and cooking.
  • T. Venkanna: His Hyderabad studio is a "charged space" featuring large nudes and printmaking machines.
  • Jayashree Chakravarty: Her Kolkata studio is a "living breathing field" where she is known to draw everywhere—even while cooking dinner.
  • Mithu Sen: Her Surajkund workplace is a labyrinth of hoarded curiosities—dolls, mermaid skeletons, and toys—which she calls an "un-studio" that can be packed into suitcases.
  • Kulpreet Singh: His Patiala workspace reflects his poetic protests on land issues, containing timber, hay, and a parked tractor.
  • Paramjit Singh: Known for vivid landscapes, his black-and-white portraits emphasize the power of his lines. His studio runs parallel to his wife Arpita’s, whom he is often seen assisting.

The article titled "A Walk in the Woods" is written by Neha Sinha, a conservation biologist and author. It explores the themes of foraging, the seasonal nature of wild foods, and the concept of sharing nature's bounty with other creatures.

The Shared Balcony Garden

The narrative begins with the author observing a mottled, creeping caterpillar on a Curry patta plant after a sudden April shower. The plant, which sits in a pot on a third-floor balcony, serves as a "breakfast champion," providing leaves for upmas and curries. The author realizes that she is sharing the plant with two caterpillars, observing how many leaves have been eaten and how many remain for "further insectile exploration".

Foraging in the Delhi Ridge

The author describes walking through the Delhi Ridge in March, noting the changing colors of deciduous trees like the semal and kusum. She highlights the Papdi tree (Holoptelea integrifolia), whose serpentine roots trail over Aravalli rocks. By April, the tree's seeds—flat and shaped like UFOs—turn from glossy green to nut brown. Foraging for these seeds is described as a seasonal ritual and a "wild, sun-warmed snack". Peeling and cracking these "Papdi disks" becomes a meditative act that helps slough off layers of fatigue.

The Lessons of Wild Food

The article reflects on the deeper meaning of foraging:

  • No Instant Gratification: Unlike store-bought food, wild food requires waiting for the right season and embracing its "beauty of its imperfections".
  • Shared Food: Wild food is fundamentally shared with animals; for instance, humans often gather Mahua flowers that have been dropped or partially eaten by birds like parakeets and hornbills.
  • Reciprocity: Drawing on the writings of scientist Robin Wall Kimmerer, the author emphasizes the need to give back to nature. This includes planting native trees and leaving fallen leaves on the ground to provide homes for insects.

Reflections on Waiting

Upon returning to her balcony, the author finds most of the Curry leaves gone and the caterpillars moved on, likely into pupation. Though she could have bought leaves at a store, she chooses to wait for the plant to regrow using sunlight and glucose. She concludes that while buying is an option, "waiting for something seemed immeasurable in its value".


The article titled “A pay-per-view performance,” appearing in the “Stream of Stories” column by Raja Sen, provides a review of the Apple TV series Margo’s Got Money Troubles, which is based on the novel by Rufi Thorpe,,.

The Plot and Characters

The story follows Margo (played by Elle Fanning), a bright college student and aspiring writer who enters into an ill-advised affair with a married professor and ends up pregnant. Her mother, Shyanne (Michelle Pfeiffer), is a former Hooters waitress and single mother herself who initially advises against having the baby, warning Margo that it will "wreck everything",. Despite her own flaws, Shyanne is described as a "broken and beautiful character" who is brutally honest about her limited skill set, claiming she is "terrible at everything... except being pretty".

The series graphically depicts the "epic slog" of motherhood as Margo tries to care for her son, Bodhi, while dealing with a sore body, a crying infant, and the impossibility of maintaining a waitressing job without childcare. Desperate to make ends meet, Margo—encouraged by her cosplaying roommate Susie—decides to start an OnlyFans account,. She approaches this new venture with the mind of a creative, developing "wildly original ideas" for explicit content.

The dynamic changes further with the arrival of Margo's father, Jinx (Nick Offerman), a "fabulist" and retired pro-wrestler recently out of rehab,. Offerman portrays Jinx with a grizzled baritone, bringing a unique perspective to the household, such as explaining that the effort of decorating a Christmas tree is meant to make moments last forever.

Thematic Parallels

The series explores the idea that in a world where everyone is performing for social media, an OnlyFans account is not an extreme leap. A central theme is the parallel between the artfulness of adult performance and the pageantry of pay-per-view pro-wrestling. Both are described as make-believe worlds of "scripted 'sports entertainment'" where performers wear makeup and adopt "gimmicks"—acting as either the good "faces" or the evil "heels" while struggling to survive.

Critical Reception

Sen highly praises the ensemble cast:

  • Elle Fanning: Described as "preternaturally gifted" and one of the finest of her generation, her "sunny smile" powers the character through "miserably rough" circumstances.
  • Michelle Pfeiffer & Nick Offerman: Both are noted as "super," with a special mention of Nicole Kidman, whose appearance in the series is described as "gasp"-inducing.
  • Production: Legendary showrunner David E. Kelley is credited with effectively deploying lines from the novel, while Fanning’s delivery is compared to "elbow-drops from the top rope".

Ultimately, the article describes the series as a touching exploration of human mistakes and the universal nature of performance, concluding that "all sex-work is art" and that everyone, in their own way, is a performer trying to get by,.


The article titled "How rising heat forces street vendors to take on more debt," written by independent journalist Anuja, explores how extreme temperatures are eroding the incomes of informal workers in India and trapping them in cycles of financial struggle.

The Human Cost of Heat

The narrative centers on Savitri, a 48-year-old street vendor in Delhi who trades utensils for old garments door-to-door, often carrying a headload of over 20kg for 10 hours a day. Last June, Savitri suffered a heat stroke and was unable to work for two weeks; the resulting loss of income forced her to borrow ₹2,000 from relatives and take ₹5,000 worth of goods on credit. Ten months later, she is still struggling to repay that money. Savitri notes that customers are scarce on hotter days, and the savings she accumulates in winter are quickly exhausted by the demands of summer. Her work hours are often halved during peak heat, and her responsibilities at home increase as family members fall ill with heat-related ailments.

Widespread Economic Impact

Research from Women in Informal Employment: Globalizing and Organizing (WIEGO) confirms that Savitri’s experience is part of a broader trend in Delhi. Survey data collected when temperatures exceeded 46 degrees Celsius revealed that 96% of vendors reported fewer customers and 90% had to reduce their working hours. Additionally, 79% of vendors—four times the number reported before peak summer—sought medical care for heat-related illnesses.

The financial fallout is severe:

  • Increased Debt: 81% of vendors reported an increase in debt during the summer.
  • Gender Disparity: While debt rose for everyone, the increase was sharper for women (50 percentage points) compared to men (40 percentage points).
  • Lack of Safety Nets: Shalini Sinha of WIEGO notes that women vendors often lack access to formal credit or social protection, forcing many to rely on "loan sharks".

Infrastructure and Night-time Stress

The article also highlights Mamata, a reseller who took a ₹50,000 bank loan to cover household and medical expenses after her husband suffered heat exhaustion. Mamata and others emphasize that night-time heat is also rising, a claim supported by a Centre for Science and Environment (CSE) study showing that megacities are not cooling down at night. This lack of overnight cooling prevents the body from recovering from daytime stress.

Compounding these issues is an "acute infrastructure deficit". Over 70% of vendors lack access to basic amenities like shade, clean water, or toilets. Mamata observes that many women vendors avoid drinking water altogether while working because there are no clean public toilets available, even at fixed market sites.

Policy and Future Outlook

Experts suggest that Heat Action Plans (HAPs) must evolve into implementation frameworks that include shaded rest areas, hydration stations, and adjusted working hours. There is also a push to design "climate-resilient vending zones" with cooling and storage facilities.

However, for those currently on the streets, the outlook remains bleak. As Mamata concludes, the poor cannot be prepared for such extremes because they can neither fight "God nor governments".


The article titled "Indian stocks catch their breath as global markets power ahead," written by Mayur Bhalerao with contributions from Dipali Banka, analyzes the recent cooling of the Indian stock market following a period of high performance.

Market Performance and Global Context

While the previous week saw a nearly 6% surge—the strongest in over five years—the pace of growth for the Nifty 50 and Sensex moderated to just over 1% for the week ending April 17. On Friday, both indices closed approximately 0.65% higher, with the Nifty at 24,353.55 and the Sensex at 78,493.56.

In contrast, global markets significantly outperformed Indian benchmarks:

  • South Korea’s Kospi: Jumped around 6%.
  • Nasdaq (US): Gained over 5%.
  • Other Asian Markets: Indonesia, Taiwan, and Japan saw rises of 2–4%.

Karan Aggarwal of Ametra PMS explained that the global rally is largely driven by an AI-powered tech surge in the US, Korea, and Taiwan—a factor that is largely absent in the Indian market.

Challenges for Indian Markets

Aggarwal highlighted "twin headwinds" currently facing India:

  1. High Valuations: The NSE 500 is trading at a price-to-earnings (P/E) ratio of 24x.
  2. EPS Re-rating Risk: There is concern regarding earnings per share (EPS) growth, which is currently around 10%.

Additionally, the market is weighed down by a muted outlook for the IT sector and lower banking treasury income.

Mixed Corporate Earnings

The article notes that investor attention has shifted to corporate earnings, which have provided a mixed picture:

  • TCS: Reported a sequential revenue rise of 3% ($7.73 billion), though net profit was slightly down by 1%.
  • Wipro: Delivered a "muted" performance with 0.2% revenue growth and a cautious forecast for FY27, citing delays in ramping up a large client.

Harshal Dasani of INVasset PMS characterized the IT sector as being "split rather than broken," noting that while TCS showed strength, Wipro's guidance served as a reminder that demand recovery remains uneven.

Sector-Specific Trends

Market activity has become highly selective, focusing on specific sectors rather than broad momentum:

  • Top Gainers: The BSE Power index led with a 6.8% rise, followed by capital goods (5.4%) and metals (over 4%).
  • Metals: These are currently benefiting from a weakening US dollar index.
  • Accumulation Opportunities: Investors are using cooling global yields to accumulate stocks in capex-heavy sectors like defence and realty, which saw sharp corrections earlier in March.
  • Weak Sectors: Auto stocks remained weak (BSE Auto index down 0.5%) due to muted demand expectations.

With macro risks remaining in play and earnings still unfolding, experts expect the Indian markets to remain range-bound in the near term.


Nifty, Sensex score handsome gains on optimism over Iran-US talks

BACK WITH A BANG. Midcap and Smallcap indices steal the show, rising 15% and 17% in the last 15 days

Anupama Ghosh Mumbai

The markets closed Friday’s session on a positive note, extending gains for the fifth consecutive day, as easing West Asia tensions, softer crude prices, and a strengthening rupee kept investor sentiment constructive — even if the pace of the rally dialled down from earlier in the week. The BSE Sensex settled at 78,493.54, gaining 504.86 points, while the Nifty 50 closed at 24,353.55, up 156.80 points. For the week, the Nifty gained 1.3 per cent, capping a remarkable 10-session run that has seen the index rally nearly 10 per cent from its recent lows.

Siddhartha Khemka of Motilal Oswal said, “Indian equities are likely to consolidate at higher levels next week,” with the critical monitorable being the second round of US–Iran diplomatic talks, as a ceasefire deadline of April 22 fast approaches.

BROAD RALLY

Broader markets once again outpaced the benchmarks, with the Midcap 100 rising 1.3 per cent and the Smallcap 100 gaining 1.5 per cent today. Over the past 15 sessions, the Smallcap index has rebounded nearly 17 per cent, while the Midcap index has recovered around 15 per cent.

FMCG SHINES

The dominant theme of the session was a decisive rotation into defensives, with the Nifty FMCG index surging over 2.6 per cent. Hindustan Unilever and Nestle India were the top Nifty gainers on the day. IT was the sole sectoral laggard, as Wipro and HDFC Life closed with losses following earnings-related concerns.

As the geopolitical backdrop continued to ease, crude oil prices were pushed lower. India VIX declined below the 18 mark to around 17.7, its lowest level since the onset of recent tensions, signalling a gradual unwinding of the conflict-driven risk premium.

Hariprasad K, SEBI-registered Research Analyst and Founder of Livelong Wealth, noted, “The market appears to be transitioning into a more stable phase after recent volatility, supported by easing geopolitical risks, cooling volatility, and sectoral rotation”. On the technical front, the Nifty held firmly above its 50-day EMA and has now ended three consecutive weeks in the green, the first such streak since November 2025.

Ajit Mishra of Religare Broking flagged that gains remained capped due to stock-specific pressure, particularly in select heavyweight names following earnings concerns, along with cautious positioning ahead of key results from private banking majors.


China suspends import licences of 3 Indian rice exporters

STRATEGIC RETORT. The government may take reciprocal steps if China continues with the suspension as the ground on which the decision was taken is not legally valid, sources said

Prabhudatta Mishra New Delhi

A month after rejecting consignments from three Indian rice exporters due to traces of genetically modified organisms (GMOs), China has cancelled the import licences of these companies, effective April 17, according to sources. The Indian Embassy in China communicated the matter to Apeda, India’s official agricultural export promotion body, which subsequently informed the companies.

RECIPROCAL STEPS?

The companies involved are NM FoodImpex Pvt Ltd, Shriram Food Industry Ltd and Sponge Enterprises Pvt Ltd. Industry sources said the government may take reciprocal steps if China continues with the suspension, as they believe the ground on which the decision was taken is not legally valid.

The exporters have reportedly approached Commerce Minister Piyush Goyal, Apeda, and the Indian Council of Agricultural Research (ICAR) to take up the matter with China on a priority basis. They added that the Chinese Customs Department’s order followed testing by the China Certification and Inspection Group (CCIC), a state-owned company, even though India has not yet permitted the commercial cultivation of GM crops, other than cotton.

Industry sources noted that while China flags Indian rice for GMO traces, China itself grows GM rice.

EXPORT TRENDS

Rice exports to China in 2024-25 were valued at $79.43 million. In the April-January period of the last fiscal, exports reached 1,86,013 tonnes, which was higher in volume but lower in value ($65.59 million) compared to the previous year.

Historically, exports were very low due to non-tariff barriers, with only 567 tonnes shipped in 2019-20. However, shipments surged to 3,31,571 tonnes in 2020-21 after Beijing removed those curbs.

RISING IMPORTS

According to USDA data, China’s rice imports for 2025-26 are estimated to rise to 3.1 million tonnes (mt) from 2.3 mt in 2024-25. Its exports are also expected to increase to 1.9 mt (from 1.2 mt), while production is pegged to grow slightly to 146.3 mt.


India’s AI value paradox

Even as infrastructure expands, enterprise adoption of AI is progressing unevenly. AI is firmly on boardroom agendas.

BEYOND DATA CENTRES. While India is becoming a key location for AI infrastructure, it is still building depth in creating the technologies that run on it.

VIPIN SONDHI & MEGHA SINGH CHAUHAN

India’s development story has long been measured in concrete and steel. Highways stretch across States, metro networks cut through urban corridors and airports expand to accommodate a growing economy. Yet alongside these assets, another infrastructure revolution is quietly unfolding, largely hidden from view.

Inside facilities with rows of servers, a new digital backbone is taking shape. Data centres are emerging as invisible highways of the digital economy, storing data, powering algorithms and enabling cloud services enterprises rely on. Driven by policy incentives and rising demand, India’s data centre sector is seeing significant multi-billion-dollar investments. Hyperscale infrastructure is expanding rapidly, positioning the country as a key node in the global digital economy.

Yet this expansion raises a deeper question: is India not only building the backbone of the AI economy, but also capturing its full value?.

HARDWARE SANS OWNERSHIP

India’s rise as a destination for digital infrastructure rests on strong fundamentals; competitive costs, a large technology workforce and a fast-growing digital market. These advantages make it an attractive base for global cloud and AI infrastructure. However, this surge contrasts with more modest progress in domestic AI innovation.

India accounts for 2-3 per cent of global AI patent filings, while the US and China together dominate the field. While India ranks among leading countries in AI research output, its share of highly cited work remains limited. Public spending on research and development, at 0.6-0.7 per cent of GDP, continues to lag leading innovation economies.

This is reflected in global benchmarks such as the Stanford AI Index, where India ranks behind the US and China across key dimensions including research, investment and compute capacity. The pattern is familiar: strength in scale and adoption, with constraints in capital and compute-intensive innovation. The implication is clear. India is becoming an important location for AI infrastructure, but is still building depth in creating the technologies that run on it.

The servers may increasingly sit in India. The most powerful models often do not. In economic terms, the pattern is familiar. The inputs of the digital economy — data, infrastructure and engineering talent — are increasingly abundant domestically. The highest-value outputs — models, platforms and intellectual property — are still largely developed elsewhere.

This gap is not only visible at the national level; it is equally evident within firms. Many organisations have access to advanced digital infrastructure but are still evolving their ability to translate it into productivity gains. Cloud adoption often takes the form of migrating legacy systems rather than redesigning workflows around real-time data and automation.

A common pattern is visible across sectors. In one mid-sized manufacturing firm that recently migrated its enterprise systems to the cloud, production dashboards update in real time across plants. Yet procurement approvals still move through multiple layers of manual sign-off, delaying decisions by days. The data moves instantly; the organisation evolves more gradually.

This underutilisation mirrors a broader national challenge. The issue is not only access to infrastructure, but the pace of building capability around it.

THE TALENT PARADOX

India produces one of the largest pools of technology professionals. Yet the requirements of the AI era are different. Artificial intelligence depends on deep research capability, advanced mathematics and sustained experimentation. While India has scale, it continues to expand the pool of researchers working at the frontier of AI development. Much of the ecosystem remains oriented towards implementation over foundational innovation.

This creates a talent paradox: a vast workforce with strong execution capability, alongside a growing but still limited base engaged in building core technologies. The emerging need is for “T-shaped” talent; professionals with deep domain expertise combined with the ability to apply AI tools across functions. This will require continued evolution in both corporate training and academic ecosystems.

Even as infrastructure expands, enterprise adoption of AI is progressing unevenly. AI is firmly on boardroom agendas. Large enterprises are building internal capabilities and experimenting across functions. However, mid-sized firms remain more measured, reflecting cost, organisational readiness and uncertainty around returns. Many organisations are developing structured approaches to measuring returns on AI investments. As a result, experimentation often precedes large-scale deployment.

A deeper issue is structural. Many firms are moving from layering AI onto existing processes to redesigning operations around it. Evidence suggests a small group is realising significant gains, while many remain in earlier stages.

THE STARTUP DIVIDE

India’s startup ecosystem reflects a similar duality. A segment risks falling into ‘AI-washing’, where artificial intelligence is emphasised even when the underlying technology is limited. Some firms act largely as intermediaries, building interfaces on top of global AI models rather than developing original capabilities.

At the same time, a smaller group pursues deeper innovation. Startups such as Sarvam AI and Krutrim are building language models tailored to India’s linguistic diversity. Qure.ai is applying computer vision to healthcare diagnostics, while CropIn is using AI to improve agricultural outcomes.

These efforts suggest that India’s AI innovation may evolve through domain-specific solutions, complementing global developments with locally relevant applications.

India’s digital infrastructure expansion is real and significant. Robust data centres, connectivity and computing capacity are essential for participation in the AI economy. India’s progress so far reflects a clear policy push towards building digital public infrastructure and enabling large-scale private investment in data centres and connectivity. This has created a foundation few emerging economies have matched. The next phase will require an equally sustained focus on innovation capability and enterprise transformation.

Capturing the full value of artificial intelligence will depend on how this transition is managed. Policymakers will need to complement infrastructure incentives with support for research and indigenous model development. Enterprises will progressively move from experimentation to embedding AI in core operations, while investors support deep-technology ventures with longer horizons.

India already possesses key advantages; scale, talent and data. The opportunity now is to translate these strengths into sustained innovation.

If current trends continue, India may host a significant share of AI infrastructure. The larger opportunity lies in ensuring it also participates in creating the intelligence that runs on it. The real challenge lies beyond the data centres; in building the capabilities that determine how value is created and captured in the age of artificial intelligence.


Sondhi is former MD & CEO of Ashok Leyland and JCB India, and Chauhan is with the Policy Unit of Quality Council of India. Views are personal.


Adani may invest ₹1 lakh cr in Mumbai’s Motilal Nagar re-development scheme

Our Bureau Mumbai

The Adani Group may invest around ₹1 lakh crore in the Motilal Nagar cluster development scheme, which is the first of 12 such projects intended to transform the Mumbai skyline.

A total of twelve cluster development projects, covering over 900 acres, are being planned by the Maharashtra Housing and Area Development Authority (MHADA). These initiatives are designed to provide improved amenities for local residents while creating commercial development opportunities for builders.

The inaugural project to commence is the re-development of the 143-acre Motilal Nagar located in Goregaon, western Mumbai. MHADA CEO Sanjeev Jaiswal stated that this specific project could involve a total investment of ₹1 lakh crore spanning a period of 10-15 years.

RESIDENTIAL UNITS

Under the scheme, the Adani Group will provide residential units to MHADA and develop various amenities within the area. Construction at Motilal Nagar is slated to begin next month, with an additional 11 development projects currently in the pipeline.


Share buy-back is capital reduction, cannot be taxed: Delhi HC

Shishir Sinha New Delhi

The Delhi High Court has ruled that share buy-back is capital reduction, not acquisition of assets, and as a result, it cannot be taxed.

“The view which the AO (Assessment Officer) had taken in treating the buy-back of shares of the company to be a transaction leading to generation of profit/ deemed profit is clearly flawed and untenable in the eye of law,” a Division Bench of Justices Dinesh Mehta and Vinod Kumar said in a recent ruling.

According to the Bench, Section 68 of the Companies Act expresses that the buy-back of shares is reduction of the share capital. There can be no doubt that as per Sub-Section (vii), the respondent-company must have mutilated or destroyed the shares or so-called property, which the AO has sought to tax.

Hence, “the very hypothesis that the respondent-company had acquired an asset at a lesser rate than the fair market value has no legs to stand on. Buy-back of its own shares is the antithesis to buying an asset,” the bench said.

It may be noted that per the Companies Act, 2013, after the completion of the buy-back under this Section, the company needs to extinguish and physically destroy the shares or security so bought back.

Sandeep Sehgal, Partner at AKM Global, said that the ruling is a significant reaffirmation of first principles. A buy-back is fundamentally a capital restructuring exercise as it leads to extinguishment of shares and a corresponding reduction in share capital, rather than any acquisition of property by the company. In that context, attempting to invoke Section 56(2)(x) on the premise of ‘receipt’ at an undervalue seems to be conceptually misplaced.

BRINGS IN CLARITY

The judgment aligns the tax treatment with the underlying legal character of the transaction under company law. The ruling also implicitly cautions against an overly expansive reading of deeming provisions, particularly where they are applied outside their intended scope.

“From a practical standpoint, this provides much-needed certainty to taxpayers and avoids the risk of unintended taxation in genuine corporate actions like buy-backs. It reinforces the principle that tax outcomes should follow the substance and legal form of the transaction, rather than a strained interpretation of anti-abuse provisions,” he said.

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