The assessee satisfied the Tribunal as to the identity and creditworthiness of the share applicant companies. In examining the creditors of the share applicant companies, the Tribunal perused the share applicant companies’ financial statements and noted that they possessed sufficient funds, and that the amounts invested in the purchase of shares were negligible in comparison to their overall creditworthiness. The Tribunal further observed that the source of the share application money had already been taxed in the hands of the share applicants, and therefore, taxing the same amount again in the hands of the assessee company would amount to double taxation. Accordingly, it was held that no substantial question of law arose for consideration in the appeal. (AY. 2012-13)