ITAT says Section 68 Cannot Tax Earlier Year Share Capital

Mantarav Private Limited received share capital and premium from various investors, including a SEBI-registered venture capital fund and a non-resident fund. 

ITAT held that earlier-year share receipts converted from OCPS to CCPS could not be taxed again under Section 68, the statutory exception for venture capital funds applied, and the foreign investment was supported by sufficient regulatory and banking evidence. The entire addition was deleted.