Allowing the appeal of the Revenue the Court held that  the order passed by the Tribunal was set aside and the order passed by the Commissioner (Appeals) was restored. The Commissioner (Appeals) had analysed the three principles which were required to be fulfilled, namely identity, creditworthiness and genuineness of the transactions. It was not in dispute that the investors were all either group companies or had common set of directors. The Commissioner (Appeals) had proceeded to analyse the data which was made available in the form of return of income, bank statements, etc., and found that the investors had purchased the shares at a premium. The fixing of rate for premium was arbitrary and devoid of any financial or accounting rationale. On analysing the data which was available it was seen that each of the companies had invested in each other and the investments had been made by rotating funds from one account to another. The assessee had not been able to explain as to why the investor companies had applied for shares in the assessee’s company at a high premium even though the face value of the share was Rs. 10 per share. The pattern of transactions clearly showed that these investor companies had raised capital by issue of shares at a very high premium and the transaction was repetitive. Therefore, the mere fact that the transactions were through banking channels or that the companies were Income-tax assessees or registered with Registrar of Companies could in no manner be sufficient to discharge the onus under section 68. The Tribunal did not examine the factual matrix in depth and in the manner it ought to have been done. Therefore, the findings rendered by the Tribunal that the assets in the form of investments had been created through rotating of money in between the group companies and the assets mainly consisted of cash and cash equivalents were not enough to prove that any unaccounted money of the assessee had been introduced in the assessee warranting addition under section 68 were perverse. The addition made under section 68 for the assessment year 2012-13 is  justified.(AY. 2012-13)