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    <title>2026 (6) TMI 1322 - ITAT MUMBAI</title>
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    <description>Share-sale proceeds supported by contract notes, demat records, bank statements and broker documentation could not be treated as unexplained income under section 68 where the revenue produced no specific adverse material linking the assessee or broker to price rigging or accommodation entries. General investigation reports and suspicion were insufficient to displace primary evidence, so the section 68 addition was deleted. The consequential addition under section 69C, being a notional commission on the same transaction, also failed once the principal addition fell and no independent basis for expenditure was shown. The additions for unexplained share-sale income and unexplained expenditure were therefore set aside in favour of the assessee.</description>
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      <title>2026 (6) TMI 1322 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=793941</link>
      <description>Share-sale proceeds supported by contract notes, demat records, bank statements and broker documentation could not be treated as unexplained income under section 68 where the revenue produced no specific adverse material linking the assessee or broker to price rigging or accommodation entries. General investigation reports and suspicion were insufficient to displace primary evidence, so the section 68 addition was deleted. The consequential addition under section 69C, being a notional commission on the same transaction, also failed once the principal addition fell and no independent basis for expenditure was shown. The additions for unexplained share-sale income and unexplained expenditure were therefore set aside in favour of the assessee.</description>
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