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MCA Compliance

Buyback of Shares Under Section 68 — Complete Guide 2026

VS Vikas Sharma 📅 March 25, 2026 ⏱️ 6 min read 👁️ 5 views

What Is Buyback of Shares?

Buyback is the process by which a company purchases its own shares from existing shareholders, effectively reducing the total number of shares outstanding. The bought-back shares are extinguished (cancelled) — they cannot be reissued. Buyback serves multiple purposes: returning excess cash to shareholders, improving earnings per share (EPS), supporting share price, providing an exit to shareholders without the company paying dividend (which is taxed in shareholders' hands), and restructuring the capital base.

Section 68 of the Companies Act, 2013 allows companies to buy back their own shares subject to strict conditions and limits. The provision balances shareholder returns with creditor protection — ensuring companies do not deplete their capital to the detriment of creditors.

Conditions for Buyback — Section 68(2)

A company can buy back its shares only if:

(a) Authorization in AOA: The articles of association must authorize buyback. Table F (model AOA) includes this power. If your AOA does not authorize: first alter AOA by special resolution.

(b) Resolution: Board resolution (for buyback up to 10% of paid-up + free reserves) OR Special resolution (for buyback between 10% and 25%).

(c) Maximum limit — 25%: The buyback in any financial year must not exceed 25% of the aggregate of paid-up share capital and free reserves. Additionally, the buyback of equity shares in any financial year must not exceed 25% of total paid-up equity capital.

(d) Post-buyback debt-equity ratio: After buyback, the ratio of secured and unsecured debts owed by the company must not be more than 2:1 (debt cannot exceed twice the remaining capital and reserves). Companies can specify a higher ratio in their AOA.

(e) Shares must be fully paid up — cannot buy back partly paid shares.

(f) No default: The company must not have defaulted in repayment of deposits, redemption of debentures/preference shares, payment of dividend, repayment of term loans, or payment of statutory dues.

(g) Cooling period: Cannot make another buyback within 1 year from the date of closure of the preceding buyback (1-year gap between two buybacks).

Two Routes for Authorization

Route 1: Board Resolution — Up to 10%

If the buyback amount does not exceed 10% of total paid-up capital and free reserves: Board resolution is sufficient. No shareholders' meeting needed. This is the simpler route — used by many private companies for small buybacks. Board passes resolution specifying: maximum number of shares, maximum price, source of funds, and timeline.

Route 2: Special Resolution — 10% to 25%

If the buyback exceeds 10% but is within 25%: special resolution at general meeting is required. The notice must specify: maximum number of shares, maximum price, source of funds, timeline, and necessity for buyback. 21 clear days notice. 75% majority required.

Sources of Funds for Buyback

Buyback can be funded ONLY from:

(a) Free reserves — accumulated profits available for distribution

(b) Securities premium — amounts received above face value on share issuance

(c) Proceeds of any securities issue — only for buyback of a different class of shares (e.g., proceeds from debenture issue to buy back equity)

Buyback CANNOT be funded from: share capital account, capital reserve, revaluation reserve, or borrowed funds. The company must have sufficient free reserves/securities premium to fund the entire buyback price.

Buyback Methods

For Listed Companies

(a) Tender offer: Company makes an offer to all shareholders to tender (sell) their shares at a specified price. Pro-rata acceptance if oversubscribed. Most common method — used by TCS, Infosys, Wipro, HCL for their buybacks.

(b) Open market: Company purchases shares through the stock exchange at prevailing market price (through a broker). Now PROHIBITED by SEBI since 2024 (for listed companies).

For Private/Unlisted Companies

(a) Proportionate basis from all shareholders: Offer to all shareholders proportionally (similar to listed company tender).

(b) From specific shareholders: Buy back from identified shareholders (commonly used when a shareholder wants to exit). Must comply with Section 68 conditions.

(c) Odd lot shares: Buyback of small fractional holdings to clean up the shareholder register.

Procedure for Buyback (Private Company)

Step 1: Board/Shareholder Approval

Board resolution (up to 10%) or special resolution (10-25%). Resolution must specify: maximum shares, maximum price per share, aggregate consideration, source of funds, timeline, and class of shares.

Step 2: Declaration of Solvency (SH-9)

Before making the buyback, Board must make a declaration of solvency in Form SH-9 — verified by an affidavit — that the company is able to pay its debts and will not become insolvent after the buyback. File SH-9 with ROC within 7 days of the declaration.

Step 3: File Letter of Offer (SH-10)

Issue Letter of Offer to shareholders in Form SH-10 — specifying: buyback price, number of shares, record date, last date for acceptance, payment timeline, and conditions.

Step 4: Accept Tenders and Make Payment

Shareholders who accept the offer tender their shares. Company accepts and makes payment within specified timeline. For oversubscription: accept proportionally from all tendering shareholders.

Step 5: Extinguish Shares

Bought-back shares are EXTINGUISHED (permanently cancelled) within 7 days of the last date of completion of buyback. The shares cease to exist — they cannot be reissued, re-allotted, or resold. Paid-up capital is reduced by the face value of extinguished shares.

Step 6: File SH-11 with ROC (Within 30 Days)

File Form SH-11 (Return of buyback of securities) with ROC within 30 days of completion of buyback. Attachments: declaration of solvency, Board/shareholder resolution, details of shares bought back, source of funds, and post-buyback capital structure.

Step 7: Transfer to Capital Redemption Reserve

Under Section 69: create a Capital Redemption Reserve (CRR) equal to the nominal (face) value of shares bought back. Transfer from free reserves to CRR. CRR can be used only for issuing fully paid bonus shares — it cannot be distributed as dividend or used for any other purpose. This protects creditors by ensuring capital is not permanently depleted.

Tax Treatment of Buyback

For the Company

Section 115QA: the company must pay buyback tax at 20% (plus 12% surcharge + 4% cess = effective 23.296%) on the distributed income — which is: (buyback consideration - amount received by the company for issue of those shares). This tax is paid by the company BEFORE distributing buyback proceeds to shareholders.

Example: Company issued shares at Rs. 10 each. Buys back at Rs. 100 each. Distributed income = Rs. 90 per share. Buyback tax = 23.296% of Rs. 90 = Rs. 20.97 per share. Company pays Rs. 100 to shareholder + Rs. 20.97 to government = total cost Rs. 120.97 per share.

For the Shareholder

Section 10(34A): Income received by the shareholder from buyback is EXEMPT from tax in the shareholder's hands. No capital gains tax on the buyback proceeds. This is the key advantage of buyback over dividend — dividend is taxable at the shareholder's slab rate, while buyback proceeds are tax-free for the shareholder (the company bears the buyback tax instead).

Buyback vs Dividend — Tax Comparison
For shareholders in the 30% tax bracket: Dividend: taxed at 30% + surcharge + cess in shareholder hands (up to 42.74%). Buyback: TAX-FREE for shareholders (company pays 23.296% buyback tax on distributed income). For promoters wanting to extract cash from the company: buyback is often more tax-efficient than dividend — especially when the original issue price was low (maximizing the distributed income base for buyback tax) and the shareholder is in the highest tax bracket.
Disclaimer
This article is for informational purposes only. Consult a qualified professional before acting. TaxClue accepts no liability. Drafts/templates are illustrative only.

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❓ Frequently Asked Questions
What is the maximum limit for buyback of shares?
Maximum 25% of aggregate of paid-up share capital and free reserves in any financial year. Additionally, buyback of equity shares cannot exceed 25% of total paid-up equity capital in that year. The limit is calculated based on the audited Balance Sheet of the preceding financial year. For buyback up to 10% of paid-up + free reserves: Board resolution sufficient. Between 10-25%: special resolution required. No buyback can be made within 1 year of completion of the preceding buyback.
Is buyback tax-free for shareholders?
Yes — under Section 10(34A), income received by shareholders from buyback is completely EXEMPT from income tax. No capital gains tax applies. The tax burden shifts to the COMPANY — which pays buyback tax at 20% (plus surcharge and cess, effective ~23.3%) on the 'distributed income' (buyback price minus issue price of those shares) under Section 115QA. This makes buyback more tax-efficient than dividend for shareholders in higher tax brackets.
Can a private company do buyback of shares?
Yes — private companies can buy back shares under Section 68, subject to all conditions: AOA authorization, Board/special resolution, maximum 25% limit, post-buyback debt-equity ratio not exceeding 2:1, no outstanding defaults, declaration of solvency (SH-9), filing SH-11 with ROC within 30 days. Private company buyback is simpler than listed company (no SEBI compliance, no open market purchase). Common use: providing exit to a departing shareholder, returning excess cash to promoters, or restructuring shareholding.
What happens to shares after buyback?
Bought-back shares are permanently EXTINGUISHED (cancelled) within 7 days of completion of buyback. They cease to exist and cannot be reissued, re-allotted, or traded. The company's paid-up share capital reduces by the face value of extinguished shares. The company must create a Capital Redemption Reserve (CRR) equal to the face value of shares bought back — transferred from free reserves. CRR can only be used for issuing fully paid bonus shares.
What is the difference between buyback by Board route and shareholder route?
Board route: for buyback up to 10% of total paid-up capital + free reserves. Only Board resolution needed — no shareholders' meeting. Faster and simpler. Shareholder route: for buyback between 10% and 25%. Special resolution (75% majority) at general meeting required. Both routes require: declaration of solvency (SH-9), letter of offer to shareholders, extinguishment of shares, SH-11 filing with ROC, and creation of Capital Redemption Reserve. Both have the 1-year cooling period between successive buybacks.

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Vikas Sharma VERIFIED EXPERT
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