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    <title>2023 (6) TMI 1537 - ITAT MUMBAI</title>
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    <description>Documentary evidence of share purchase and sale, including banking payments, demat entries and exchange-routed trades, was treated as sufficient where the tax authority failed to disprove the records or make independent enquiry showing price rigging or accommodation entries. Reliance only on investigation reports and third-party statements, without corroboration linking the assessee, was stated to be insufficient to reject long-term capital gains exemption. The assessee&#039;s earlier withdrawal of the exemption claim was treated as made under misconception and not determinative by itself. The discussion follows precedent limiting additions based only on suspicion, human probabilities, or uncorroborated material; the share-sale additions and related commission addition were deleted.</description>
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      <description>Documentary evidence of share purchase and sale, including banking payments, demat entries and exchange-routed trades, was treated as sufficient where the tax authority failed to disprove the records or make independent enquiry showing price rigging or accommodation entries. Reliance only on investigation reports and third-party statements, without corroboration linking the assessee, was stated to be insufficient to reject long-term capital gains exemption. The assessee&#039;s earlier withdrawal of the exemption claim was treated as made under misconception and not determinative by itself. The discussion follows precedent limiting additions based only on suspicion, human probabilities, or uncorroborated material; the share-sale additions and related commission addition were deleted.</description>
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