The Assessing Officer has not made any  enquiry whatsoever, or depute an inspector or seek the help of the Investigation Wing to support the conclusion that it was a case falling under section 68. The Commissioner (Appeals) had confirmed the addition solely on the basis of low returned income of the subscribers. The assessee had filed all documents to prove its case prima facie and, thus, discharged the primary onus on it. It was for the Revenue to pick up the addresses, names, locations and carry out further investigations to prove the credibility or non-credibility of the parties, which was abysmally lacking. The order of the Commissioner (Appeals) had no iota of any tangible material. As nothing was shown to conclude that the income fell within the ambit of section 68, the action of the Commissioner (Appeals) could not be sustained. (AY. 2010-11)