Addition u/s 68 cannot be made in respect of Opening balance:

AO made an addition of Rs.10,09,000/- on account of unsecured loans. The Tribunal observes that out of the said sum, only a sum of Rs.50,000/- was received in the year under consideration and the balance was on account of opening balance. Hence, the addition was restricted to Rs.50,000/- by the Tribunal. The said view was also upheld by the Hon’ble High Court. Revenue’s appeal was dismissed accordingly.

[CIT Vs. JAGATKUMAR SATISHBHAI PATEL - TAX APPEAL NO.324 of 2012 - GHC)