Tribunal held that money advanced for acquisition of shares which is a capital asset, same cannot be treated as capital financing unless parties have intended or agreed to convert same and such an intention has to be gathered from any agreement or arrangement or understanding; if parties have treated it to be share application money for subscription of shares, then onus is upon Assessing Officer to prove it contrary that it is an international transaction. Accordingly the addition of adjustment is deleted. (AY. 2011-12)