Dismissing the appeal of the aassessee the Court held ,that  the assessee being a private limited company the burden of proof was on a higher pedestal even though the assessee had furnished the particulars of the bank accounts, passport, permanent account number card, addresses and earnings by the shareholder-cum-director and the money had been invested through banking channels . On facts it was found that  the share subscribers did not have their own profit making apparatus and were not involved in business activity. Money was routed through.Profit motive normal in the case of investment  was entirely absent .No profit or dividend was declared . Accordingly the genuineness of transactions were doubted .Appeal was dismissed  holding that no substantial  question of law  ( AY.2011-12)