The Settlement Commission’s conclusions were upheld in large measure. The Director of Industries had certified the claim, and the Assessing Officer had accepted the deduction under section 80-IC during scrutiny assessments for AYs 2006-07 to 2008-09. In respect of additions to the share capital of entity A (amounting to Rs. 37.60 crores), those additions had already been subjected to tax in assessments of entity A and the Department had identified the source of funds; therefore, the Settlement Commission erred in making further additions on that basis. Section 115BBE-which disallows special deductions for certain incomes-was inserted only by the Finance Act, 2012, with effect from 1 April 2013, and thus did not apply to the assessment years in question. The assessee had explained circumstances for surrendering income and the Department produced no material to displace the claim that the share capital was connected with the business. The Settlement Commission’s order was set aside in part (to the extent of certain additions) but, importantly, the assessee was held entitled to consequential relief and the denial of deduction under section 80IC on that ground was set aside.(AY. 2004-05 to 2010-11)