The assessee-company raised funds through Foreign Currency Convertible Bonds (FCCB). The Assessing Officer made an addition under section 68 on the ground that the assessee failed to establish the identity, creditworthiness and genuineness of the ultimate bondholders. Affirming the Tribunal’s order, the High Court held that the assessee’s onus under section 68 is discharged by proving the identity, capacity and creditworthiness of the immediate subscriber (in this case, the lead manager bank) from whom the funds were received. The assessee is not obligated to prove the identity of the ultimate beneficial owners, i.e., the “source of the source”. The Court noted that the issue was identical to that in Reliance Communications Ltd., a decision that had attained finality. Since the assessee had fully explained the nature and source of the funds received from the lead manager, the addition was held to be invalid. (AY. 2007-08)