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    <title>2026 (5) TMI 1417 - ITAT MUMBAI</title>
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    <description>Section 68 addition and disallowance of share-sale loss in a penny stock transaction were held unsustainable where the assessee produced contract notes, demat statements, bank records and other documentary proof of genuine purchase and sale through recognised exchange channels. General investigation material about scrip manipulation, without direct evidence linking the assessee to an accommodation entry operator or proving receipt of unaccounted consideration, was insufficient. The surrounding facts also did not support any sham transaction motive. Authorities cited by the Revenue were distinguished on their facts because they involved materially different claims of exempt capital gains from abnormal price appreciation.</description>
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      <description>Section 68 addition and disallowance of share-sale loss in a penny stock transaction were held unsustainable where the assessee produced contract notes, demat statements, bank records and other documentary proof of genuine purchase and sale through recognised exchange channels. General investigation material about scrip manipulation, without direct evidence linking the assessee to an accommodation entry operator or proving receipt of unaccounted consideration, was insufficient. The surrounding facts also did not support any sham transaction motive. Authorities cited by the Revenue were distinguished on their facts because they involved materially different claims of exempt capital gains from abnormal price appreciation.</description>
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