The learned assessing officer rejected the contention of the assessee and held that most of the shareholders have meager returned income, investors to not have any substantial business activities, absence of substantial fixed assets, absence of strong financials, and absence of date in the documents found during the course of search such as blank share transfer forms etc. Shows that it is a sham transaction. Thus, the learned AO made an addition of INR 481987000/– as unaccounted income of the assessee which has been introduced into the books in the form of share capital and share premium. The AO further made an addition of INR 9639750/– being 2% of the amount of share capital as commission to obtain share capital. Thus, total addition of Rs. 491626740/– was made.