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“shell company”

Cash Credits & Unexplained ItemsSection 68Section 68620 judgments

The decision most relied on for shell company is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on shell company

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Principal CIT v. Sreeleathers
448 ITR 332 · 2022 · High Court
88
citing judgments

Additions made by an Assessing Officer under Section 68 for unsecured loans or share capital/premium are perverse if based merely on an allegation of 'shell companies' without proper findings, especially when the assessee has provided evidence and lenders confirmed transactions through Section 133(6) notices.

CIT v. Varinder Rawlley
366 ITR 232 · 2014 · High Court
79
citing judgments

An assessee discharges the initial onus under Section 68 for cash credits by proving the identity and genuineness of the transaction, typically through account payee cheques, bank entries, and the creditor's PAN. The amount cannot be added as the assessee's income unless the department produces material linking the funds to the assessee or demonstrating the creditor's source flowed from the assessee, especially if the creditor is not under the assessee's control.

Major Metals Ltd. v. Union of India
19 Taxmann.com 176 · 2012 · High Court
54
citing judgments

When an unlisted company issues shares at an unjustifiably high premium to subscribers who lack the financial standing and creditworthiness, the entire transaction may be deemed not genuine, leading to the addition of the share capital and premium under Section 68 as unexplained cash credit.

PCIT v. Vaishnodevi Refoils & Solvex
89 Taxmann.com 80 · 2018 · High Court
46
citing judgments

The addition of share application money to the income of the assessee under Section 68 is not justified if the assessee has discharged the initial onus by providing complete particulars and documentary evidence of the creditor, and the Revenue has failed to prove otherwise. The Supreme Court has also dismissed the Revenue's SLP in this matter.

CIT v. Nivedan Vanijya Niyojan Ltd.
263 ITR 623 · 2003 · High Court
36
citing judgments

An assessee must establish the identity, creditworthiness, and genuineness of subscribers to share capital. Furnishing income tax file numbers alone is insufficient to discharge this burden.

48(SC) 2. Principal Commission of Income Tax v. NDR Promoters (P) Ltd.
96 Taxmann.com 602 · 2018 · High Court
27
citing judgments

The addition of share capital under Section 68 is unsustainable if the Assessing Officer issues summons to investor entities but receives no appearance, relying solely on submissions via DAK, raising doubts about investor identity and genuineness.

CIT v. Real Time Marketing (P) Ltd.
306 ITR 35 · 2008 · High Court
26
citing judgments

An addition under Section 68 for share application money cannot be made solely on the basis that the money deposited in the bank account of a third party was the assessee's money, if there is no material to link the assessee with the deposit.

Judgments citing shell company

Income Tax Officer, Mumbai vs. Haresh Kumar Manjibhai Patel, Gujarat

In the result, the appeal of the Revenue fails and is dismissed in its entirety

ITA 3633/MUM/2024[2018-19]Status: DisposedITAT Mumbai11 Sept 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 10(38)Section 144Section 147Section 68Section 69C

lower valuation than the peak, which belies the allegation of manipulative intent. 11.2. It was also explained that SRDL was not a mere shell company devoid of business; on the contrary, the annual accounts for A.Ys. 2013–14 to 2018–19, duly placed before the AO, disclosed genuine turnover

Orbis Real Estate Fund I, Hyderabad (Auth. Rep.) vs. ADIT (International Taxation)-2 - 2, Hyderabad

In the result, the appeal of the assessee is partly allowed

ITA 785/HYD/2024[2020-2021]Status: DisposedITAT Hyderabad10 Sept 2025AY 2020-2021

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri Sai Sourabh K, C.AFor Respondent: Dr. Narender Kumar Naik
Section 143(3)Section 154

treating the date of investment as the date of acquisition. 6. Per contra, the learned Departmental Representative (“Ld. DR”) submitted that, WEPL was a shell company incorporated for the sole purpose of holding land. It carried out no business activity for over a decade. She submitted that the entire structure

Income Tax Officer, Ward-1(1), Kolkata vs. Avinash Commercial Private Limited, Kolkata

In the result, the appeal of the Revenue is allowed for statistical purposes

ITA 1603/KOL/2024[2012-13]Status: DisposedITAT Kolkata08 Sept 2025AY 2012-13

Bench: Sonjoy Sarma & Sri Rakesh Mishra

Section 143(2)Section 143(3)Section 147Section 148Section 149Section 250Section 69

said company could not be traced. The Assessing Officer (hereinafter referred to as Ld. 'AO'), noted that the assessee company was nothing but a shell company which was incorporated and used for laundering unaccounted income and providing accommodation entry in lieu of commission to various beneficiaries. The Ld. AO found ... merely reproduced the submission of the assessee and granted relief without giving his reasons for the relief. The assessee is stated to be a shell company and, therefore, it was incumbent upon it to explain the source of the money received which was subsequently invested. It has been held

Narayan Suppliers Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(3), Kolkata

In the result, appeal of the assessee is dismissed

ITA 1077/KOL/2024[2011-2012]Status: DisposedITAT Kolkata08 Sept 2025AY 2011-2012

Bench: Shri George Mathan & Shri Rakesh Mishra

For Appellant: Shri Avijit Ghoshal, ARFor Respondent: Shri Raja Sengputa, CIT-DR
Section 10(38)

Narayan Suppliers Pvt. Ltd. Ak ojha Director Certified to be True Copy 9. It was the submission that this assessee itself is a shell company. The assessee has been showing loss. The assessee has shown reserves and surplus of 7,07,05,000/-. It was the submission that the transaction

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Velachery

ITA 632/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Aug 2025AY 2021-22

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

order u/s.144A is baseless. 3.5 Therefore, while the finding of the JCIT, and that of the ld.CIT(A), hold that M/s.DFPL is not a shell company. In view of our above discussion and reasoning, the grounds of appeal of the Revenue are dismissed. As a result, the order ... appreciating the fact that AO had spelt out clear reasons for his inference that the company, M/s. Bholenath Merchants P Ltd. was a shell company and the assessee had introduced a structure for routing unaccounted money back in the form of unexplained capital. ITA No.322, 323, 324, 325, 321 & 632/Chny/2025

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Chennai

ITA 325/CHNY/2025[2018-19]Status: DisposedITAT Chennai29 Aug 2025AY 2018-19

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

order u/s.144A is baseless. 3.5 Therefore, while the finding of the JCIT, and that of the ld.CIT(A), hold that M/s.DFPL is not a shell company. In view of our above discussion and reasoning, the grounds of appeal of the Revenue are dismissed. As a result, the order ... appreciating the fact that AO had spelt out clear reasons for his inference that the company, M/s. Bholenath Merchants P Ltd. was a shell company and the assessee had introduced a structure for routing unaccounted money back in the form of unexplained capital. ITA No.322, 323, 324, 325, 321 & 632/Chny/2025

Deputy Commissioner of Income Tax, Chennai vs. Kag India Private Limited, Chennai

ITA 324/CHNY/2025[2017-18]Status: DisposedITAT Chennai29 Aug 2025AY 2017-18

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

order u/s.144A is baseless. 3.5 Therefore, while the finding of the JCIT, and that of the ld.CIT(A), hold that M/s.DFPL is not a shell company. In view of our above discussion and reasoning, the grounds of appeal of the Revenue are dismissed. As a result, the order ... appreciating the fact that AO had spelt out clear reasons for his inference that the company, M/s. Bholenath Merchants P Ltd. was a shell company and the assessee had introduced a structure for routing unaccounted money back in the form of unexplained capital. ITA No.322, 323, 324, 325, 321 & 632/Chny/2025

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Chennai

ITA 323/CHNY/2025[2015-16]Status: DisposedITAT Chennai29 Aug 2025AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

order u/s.144A is baseless. 3.5 Therefore, while the finding of the JCIT, and that of the ld.CIT(A), hold that M/s.DFPL is not a shell company. In view of our above discussion and reasoning, the grounds of appeal of the Revenue are dismissed. As a result, the order ... appreciating the fact that AO had spelt out clear reasons for his inference that the company, M/s. Bholenath Merchants P Ltd. was a shell company and the assessee had introduced a structure for routing unaccounted money back in the form of unexplained capital. ITA No.322, 323, 324, 325, 321 & 632/Chny/2025

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Chennai, Tamilnadu

ITA 322/CHNY/2025[2014-15]Status: DisposedITAT Chennai29 Aug 2025AY 2014-15

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

order u/s.144A is baseless. 3.5 Therefore, while the finding of the JCIT, and that of the ld.CIT(A), hold that M/s.DFPL is not a shell company. In view of our above discussion and reasoning, the grounds of appeal of the Revenue are dismissed. As a result, the order ... appreciating the fact that AO had spelt out clear reasons for his inference that the company, M/s. Bholenath Merchants P Ltd. was a shell company and the assessee had introduced a structure for routing unaccounted money back in the form of unexplained capital. ITA No.322, 323, 324, 325, 321 & 632/Chny/2025

Deputy Commissioner of Income Tax, Central Circle-2(1), Chennai vs. Kag India Private Limited, Chennai

ITA 321/CHNY/2025[2019-20]Status: DisposedITAT Chennai29 Aug 2025AY 2019-20

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R.Raghunathaआयकर अपील सं./Ita No.322/Chny/2025, A.Y.: 2014-15 आयकर अपील सं./Ita No.323/Chny/2025, A.Y.: 2015-16 आयकर अपील सं./Ita No.324/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.325/Chny/2025, A.Y.: 2018-19 आयकर अपील सं./Ita No.321/Chny/2025, A.Y.: 2019-20 आयकर अपील सं./Ita No.632/Chny/2025, A.Y.: 2021-22

For Appellant: Mr.Bipin C.N, CIT
Section 139(1)Section 142(1)Section 143(2)Section 144ASection 153A

order u/s.144A is baseless. 3.5 Therefore, while the finding of the JCIT, and that of the ld.CIT(A), hold that M/s.DFPL is not a shell company. In view of our above discussion and reasoning, the grounds of appeal of the Revenue are dismissed. As a result, the order ... appreciating the fact that AO had spelt out clear reasons for his inference that the company, M/s. Bholenath Merchants P Ltd. was a shell company and the assessee had introduced a structure for routing unaccounted money back in the form of unexplained capital. ITA No.322, 323, 324, 325, 321 & 632/Chny/2025

ACIT(CC)-7(3), Mumbai vs. Lotus Logistics and Developers Private Limited, Mumbai

In the result, appeal by the Revenue is dismissed and cross objection of the assessee is partly allowed

ITA 137/MUM/2025[2018-19]Status: DisposedITAT Mumbai28 Aug 2025AY 2018-19

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2018-19

For Appellant: Shri Rushabh Mehta and Shri Niraj Soni, CAsFor Respondent: Shri Aditya M. Rai, Sr. DR
Section 143(3)Section 37(1)Section 43CSection 68Section 69C

income tax return acknowledgements to discharge its onus. However, ld. AO, ignoring these evidences, alleged that lender Santosh Gems Pvt. Ltd. is a shell company controlled by Shri Praveen Kumar Jain against whom search and seizure action had taken place in the past. ld. AO placed reliance on the statements

Beejay Investment and Financial Consultants Pvt. Ltd., Kolkata vs. ITO, Ward 1(1), Kolkata

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 996/KOL/2025[2013-2014]Status: DisposedITAT Kolkata27 Aug 2025AY 2013-2014

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 996/Kol/2025 Assessment Year: 2013-2014 Beejay Investment & Financial Consultants Pvt. Limited,………………….………Appellant 13, 2Nd, 205, Bipin Behari Ganguly Street, Kolkata-700012 [Pan:Aabcb0832B] -Vs.- Income Tax Officer,……………………………..Respondent Ward-1(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Miraj D Shah, A.R., Appeared On Behalf Of The Assessee Shri Soumitra Ghosh, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 20, 2025 Date Of Pronouncing The Order: August 27, 2025 O R D E R

Section 142(1)Section 147Section 148Section 271(1)(c)

Consultants Pvt. Limited help of dummy directors. From the bank accounts, it was noticed that huge amount was credited in the accounts from various shell companies and the same was transferred to various beneficiary companies. During the course of scrutiny, the assessee failed to submit any documentary evidence in support

Primerose Traders Pvt. Ltd., Kolkata vs. D.C.I.T., Circle - 5(1), Kolkata

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 2276/KOL/2024[2012-2013]Status: DisposedITAT Kolkata27 Aug 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishraassessment Year: 2012-13

For Appellant: Shri Manish Tiwari, FCAFor Respondent: Shri Raja Sengupta, CIT-DR
Section 143(1)Section 143(3)Section 147Section 148Section 250Section 68

this conversion of shares to loans/advances of Rs. 5,30,00,000/- is highly suspicious and considering the applicant company as a shell company, the AO added the full sum of Rs.5,38,00,000- In the lengthy assessment order containing 26 pages, the AO mentioned the issue only

Income Tax Officer Ward 52(1) New Delhi, New Delhi vs. M/S Novel Infratech, New Delhi

In the result appeal of the revenue is dismissed

ITA 188/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Aug 2025AY 2013-14

Bench: Shri M. Balaganesh & Shri Sudhir Kumarito, Vs. M/S. Novel Infratech, Ward-52(1), Flat No. 915, Indra Prakash New Delhi Building, 21, Barakhamba Road, New Delhi (Appellant) (Respondent) Pan: Aajfn0187A

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 131(1)(d)Section 133(6)Section 143(3)Section 68

perusal of the same, it is seen that the company has not been treated as a shell company and regular assessment disallowing an estimated addition of Rs.1 Lakhs was made in the assessment order. If in the assessment M/s. Novel Infratech order of M/s Nitin Hire Purchase ... held that it was shell company or that it was engaged in the business of giving accommodation entries, it is unjustified that the same entity is treated as accommodation entry providers in the case of the assessee. 53. Further, the assessment order for A.Y 2012-13 of Twenty First Century

Mahayana Theravada Vajrayana Buddhist Religious and Chaitable Trust, Meerut vs. ACIT Central Circle, Meerut

ITA 1709/DEL/2024[2015-16]Status: DisposedITAT Delhi27 Aug 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR
Section 142(1)Section 143(3)Section 147Section 68

amount of Rs.2,30,00,000/- was added in the hands of the assessee treating it as bogus donation from shell company controlled by Shri J.P. Gupta which was further confirmed by the First Appellate Authority. 10. Additional ground of appeal has been raised by the assessee on the ground

Mahayana Theravada Vajrayana Buddhist Religious and Charitable Trust, Meerut vs. ACIT Central Circle, Meerut

ITA 1708/DEL/2024[2013-14]Status: DisposedITAT Delhi27 Aug 2025AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR
Section 142(1)Section 143(3)Section 147Section 68

amount of Rs.2,30,00,000/- was added in the hands of the assessee treating it as bogus donation from shell company controlled by Shri J.P. Gupta which was further confirmed by the First Appellate Authority. 10. Additional ground of appeal has been raised by the assessee on the ground

Mahayana Theravada Vajrayana Buddhist Religious and Charitable Trust, Meerut vs. ACIT, Central Circle, Meerut

ITA 1682/DEL/2024[2014-15]Status: DisposedITAT Delhi27 Aug 2025AY 2014-15

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla

For Appellant: Sh. Kalrav Mehrotra, AdvFor Respondent: Sh. Manoj Tiwari, Sr. DR
Section 142(1)Section 143(3)Section 147Section 68

amount of Rs.2,30,00,000/- was added in the hands of the assessee treating it as bogus donation from shell company controlled by Shri J.P. Gupta which was further confirmed by the First Appellate Authority. 10. Additional ground of appeal has been raised by the assessee on the ground

DCIT Central Circle 30, New Delhi vs. Krrish Shalimar Projects Pvt. Ltd., Delhi

In the result, appeal filed by the revenue is dismissed and appeal filed by the assessee is allowed for statistical purpose

ITA 3097/DEL/2023[2018-19]Status: DisposedITAT Delhi27 Aug 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Amit Kumar Jain, CIT DR
Section 133(6)Section 143(2)Section 68

hands of the entity is mostly comprising of share capital and share premium received from various entities, thereby reflecting that it is a shell company used for the purpose of providing entries. 3. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred ... information submitted by the assessee, he came to the conclusion on the two companies i.e., UV Credit Solutions and Cloister Realtors that they are shell companies with the observation that the major and only source of funds to finance the assessee are the share capital and share premium, they

DCIT, New Delhi vs. Krish Shalimar Project Pvt Ltd, Delhi

ITA 2500/DEL/2023[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Amit Kumar Jain, CIT DR
Section 133(6)Section 143(2)Section 68

hands of the entity is mostly comprising of share capital and share premium received from various entities, thereby reflecting that it is a shell company used for the purpose of providing entries. 3. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred ... information submitted by the assessee, he came to the conclusion on the two companies i.e., UV Credit Solutions and Cloister Realtors that they are shell companies with the observation that the major and only source of funds to finance the assessee are the share capital and share premium, they

Krrish Shalimar Projects Pvt. Ltd., Delhi vs. Assistant Commissioner of Income Tax, Central Circle 30, Delhi

In the result, appeal filed by the revenue is dismissed and appeal filed by the assessee is allowed for statistical purpose

ITA 2347/DEL/2023[2017-18]Status: DisposedITAT Delhi27 Aug 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Amit Kumar Jain, CIT DR
Section 133(6)Section 143(2)Section 68

hands of the entity is mostly comprising of share capital and share premium received from various entities, thereby reflecting that it is a shell company used for the purpose of providing entries. 3. That on the facts and in the circumstances of the case, the Ld. CIT(A) has erred ... information submitted by the assessee, he came to the conclusion on the two companies i.e., UV Credit Solutions and Cloister Realtors that they are shell companies with the observation that the major and only source of funds to finance the assessee are the share capital and share premium, they