Held that where opening balance of share premium represented monies received in earlier years and not in relevant assessment year 2018-19, section 68 would have no application in relation thereto  addition was deleted.   Assessee received share premium from founder promoter and had discharged its burden of proving his identity, genuineness and creditworthiness. The assessee had engaged a celebrity endorser, for which her consideration was fixed and instead of making payment, assessee had allotted equity shares to her at a premium, section 68 would not have any application. In respect of ‘F’, Assessing Officer/NFAC was to be directed to confine their inquiries only to genuineness of arrangement by enquiring as to whether agreed consideration had indeed been subjected to GST and TDS, as claimed by assessee; and also manner in which consideration has been accounted by assessee and shareholder in their respective books.If arrangement was found to be in accordance to law, then no addition shall be made on this count. Additions made on share premium credited against shares was not justified.  Tribunal also held that the Revenue ought not to have simply pushed entire burden on to assessee to provide details and documents of foreign shareholders, particularly when CBDT empowered them to make independent enquiries from them. Right course of action for revenue was to make independent enquiries from these investors through appropriate channel. Revenue not having made independent enquiries, addition of share premium received from foreign investors was to be sent back to file of Assessing Officer/NFAC for de-novo assessment in respect of credit in assessee’s book, in a fair and reasonable manner and in accordance to law. (AY.  2018-19)