ORDER

Assailing the order of the respondent dated 22.03.2018, whereby the petitioner was directed to remit tax at 15% of the total payment of Rs.19415,62,77,269/- along with interest under Section 115P of the Income Tax Act (in short "Act"), the present Writ Petition has been filed.

2. According to the petitioner, it is a Company incorporated under the Companies Act and is engaged in the business of development of computer software and related services and export. In the year 2013, the petitioner bought back its own shares under Section 77A of the Companies Act. Thereafter, during the year 2016 under the Scheme of Arrangement and Compromise, the petitioner planned to purchase its own shares under Sections 391 to 393 of the Companies Act for the following reasons:-

(i) to increase earnings per share and return on equity over a period of time and enhance long-term value creation;

(ii) to streamline ownership structure by purchasing its own shares from minority shareholders holding less than 25% of the issued, subscribed and paid up share capital;

(iii) to serve the shareholders more efficiently and optimize the overall capital structure; and (iv) to reduce foreign currency fluctuation ri