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    <title>2025 (2) TMI 818 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai dismissed the revenue&#039;s appeal regarding additions under sections 68 and 69C. The assessee had claimed LTCG/STCG from penny stock sales, which the AO treated as bogus accommodation entries under section 68. The CIT(A) deleted the addition, finding the assessee discharged the primary onus despite SEBI suspending the scrip. The ITAT upheld this decision citing judicial discipline principles and consistency with the assessee&#039;s previous year case. The section 69C addition for alleged unaccounted commission expenditure was also dismissed as it was consequential to the main section 68 addition, which was decided in the assessee&#039;s favor.</description>
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      <title>2025 (2) TMI 818 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=766271</link>
      <description>The ITAT Mumbai dismissed the revenue&#039;s appeal regarding additions under sections 68 and 69C. The assessee had claimed LTCG/STCG from penny stock sales, which the AO treated as bogus accommodation entries under section 68. The CIT(A) deleted the addition, finding the assessee discharged the primary onus despite SEBI suspending the scrip. The ITAT upheld this decision citing judicial discipline principles and consistency with the assessee&#039;s previous year case. The section 69C addition for alleged unaccounted commission expenditure was also dismissed as it was consequential to the main section 68 addition, which was decided in the assessee&#039;s favor.</description>
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