1. DHC in Luthra Jewellers:
"As regards the second issue, in our view, once again the ITAT has correctly appreciated the law that no addition under Section 68 of the Income Tax Act, 1961 could have been made in respect of money introduced by the two partners of the assessee on the first day of the assessee coming into existence. The addition, if any, could have been made in the hands of the partners which the partners claimed in any event they had disclosed in their income tax returns for assessment years prior to the assessee coming into existence. We find no perversity in the view taken by the Tribunal."
To the similar effect is the 2009/latest ruling of Raj HC in Kewal Krishan and Partners.
2. DHC in E Two E Technologies:
"In this appeal the ITAT has applied the decision of the Full Bench of the Court in CIT vs Sophia Finance Ltd; 205 ITR 98 and dismissed the appeal of the Revenue. It has been observed that the identity of the share applicants had been fully established; and as had been observed by the Assessing Officer, the shares have been allotted in the subsequent years.
No substantial question of law arises for consideration.
Accordingly, the appeal is dismissed."
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