The Tribunal held that the identity of parties had been established, their Permanent Account Numbers provided and nothing Adverse Pointed Out By Assessing Officer Or Commissioner (Appeals). The amendment to section 68 by the Finance Act, 2012 with effect from April 1, 2013, placed a heavy onus on the assessee, where the sum credited consisted of the share capital, share application money and share premium. The amendment could not be said to be retrospective in nature and had to be prospective, i. e., from assessment year 2013-14. the issue of share capital and share premium were on capital account and could not be considered income of the assessee. (AY.2012-13)