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Gross sale consideration from alleged penny-stock transactions...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation entries.
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Gross sale consideration from alleged penny-stock transactions cannot be treated as undisclosed income without examining the underlying transactions and establishing a cogent nexus between the taxpayer and the alleged accommodation-entry arrangement. Recorded books, contract notes, bank statements and broker entries require specific contrary material before being disregarded. General investigation material describing a penny-stock modus operandi may justify further enquiry but does not, by itself, prove that particular transactions are fictitious or represent unaccounted money. A premise that exempt capital gains were claimed must also be supported by the return and computation. Interest on such an addition is consequential and must correspond to finally determined income.
Gross sale consideration from alleged penny-stock transactions cannot be treated as undisclosed income without examining the underlying transactions and establishing a cogent nexus between the taxpayer and the alleged accommodation-entry arrangement. Recorded books, contract notes, bank statements and broker entries require specific contrary material before being disregarded. General investigation material describing a penny-stock modus operandi may justify further enquiry but does not, by itself, prove that particular transactions are fictitious or represent unaccounted money. A premise that exempt capital gains were claimed must also be supported by the return and computation. Interest on such an addition is consequential and must correspond to finally determined income.
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