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    <title>2025 (2) TMI 1708 - ITAT MUMBAI</title>
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    <description>Penny stock long-term capital gains were treated as bogus where surrounding circumstances, SEBI findings, off-market purchase, unusual price rise, connected parties and the assessee&#039;s statement showed a sham accommodation entry; the documentary trail of bank entries, demat records and contract notes did not displace the onus under section 68, and the addition was sustained. The objection based on denial of cross-examination and non-furnishing of material failed because the assessment rested on independent inquiry and corroborative evidence, so no prejudice was shown. Once the share transaction was found sham, the commission estimate under section 69C was also upheld as a natural corollary of arranging the entry.</description>
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      <description>Penny stock long-term capital gains were treated as bogus where surrounding circumstances, SEBI findings, off-market purchase, unusual price rise, connected parties and the assessee&#039;s statement showed a sham accommodation entry; the documentary trail of bank entries, demat records and contract notes did not displace the onus under section 68, and the addition was sustained. The objection based on denial of cross-examination and non-furnishing of material failed because the assessment rested on independent inquiry and corroborative evidence, so no prejudice was shown. Once the share transaction was found sham, the commission estimate under section 69C was also upheld as a natural corollary of arranging the entry.</description>
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