High Court Finds Error in Tax Settlement on Share Capital Infusion; Questions Department's Inconsistent Positions.

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....Validity of Income Tax Settlement order - additions made with respect to the infusion of share capital and the denial of benefit of deductions u/s 80IC - second round of litigation - The Court found substantial merit in the assessee's submissions regarding the infusion of share capital. The Court concluded that the addition of INR 11.26 crores by the ITSC was unsubstantiated, especially in light of evidence suggesting the funds' availability for such investment by the implicated company in the relevant assessment years. - The High Court observed a pivotal mistake in the ITSC's handling of share capital issues, particularly failing to account for the Department's contradictory stances and the non-application of Section 115BBE of the Act, which pertains to tax on income with unexplained credit.....