Income Tax on buyback of shares Sec 115QA

Is the buyback tax payable on issue to issue basis or on aggregate basis?

Shares tendered for buyback relate to separate issues and therefore the company needs to calculate the difference between buyback price and the issue price. Refer table below for my query.

               
  Nos Issue
Price
Issue
Amount
Buyback
Price
Buyback
Amount
Taxable Amt  
 Issue 1  5,000 100 5,00,000 150 7,50,000 2,50,000  
 Issue 2  5,000 200 10,00,000 150 7,50,000 -2,50,000  
            0 Aggregate Not taxable
               
  Nos Issue
Price
Issue
Amount
Buyback
Price
Buyback
Amount
Taxable Amt  
 Issue 1  5,000 100 5,00,000 150 7,50,000 2,50,000 Taxable
 Issue 2  5,000 200 10,00,000 150 7,50,000   Not taxable
            2,50,000 Net Taxable
               
Replies (1)

Anxiously waiting for an opinion, if someone can throw some light. I did not find any mention of such a situation in the Income Tax Act...

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