Addition can not be made merely on the basis of information from Director of Income-tax (Inv.)

In respect of amount of Rs.50,07,000 alleged to have been received from Swetu Stone (P) Ltd. and Chintpurni Credits, the appellant contended before the A.O. as well as before me that they have not received any share application money from those two companies. The A.O. did not contradict this submission of the appellant. The A.O. did not confront the assessee company about the information received by him from Investigation Wing and used it against the assessee without opportunity of being heard in respect of material in his possession. The A.O. did not bring any positive evidence on the record ...