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    <title>2026 (5) TMI 823 - ITAT RAIPUR</title>
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    <description>Additions based on alleged penny stock accommodation entries were found unsustainable where the share transactions were executed through the stock exchange, securities transaction tax was paid, the shares were reflected in the demat account, and sale proceeds moved through banking channels. The assessee had also disclosed the transactions in the return of income. In the absence of direct material linking the assessee to entry operators, brokers, or any colourable device, generalized suspicion and the theory of human probabilities were insufficient to support additions under sections 68 and 69C. The Revenue&#039;s challenge therefore failed and the additions were deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791621</link>
      <description>Additions based on alleged penny stock accommodation entries were found unsustainable where the share transactions were executed through the stock exchange, securities transaction tax was paid, the shares were reflected in the demat account, and sale proceeds moved through banking channels. The assessee had also disclosed the transactions in the return of income. In the absence of direct material linking the assessee to entry operators, brokers, or any colourable device, generalized suspicion and the theory of human probabilities were insufficient to support additions under sections 68 and 69C. The Revenue&#039;s challenge therefore failed and the additions were deleted.</description>
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