Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation entries.

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....Gross sale consideration from alleged penny-stock transactions cannot be treated as undisclosed income without examining the underlying transactions and establishing a cogent nexus between the taxpayer and the alleged accommodation-entry arrangement. Recorded books, contract notes, bank statements and broker entries require specific contrary material before being disregarded. General investigation material describing a penny-stock modus operandi may justify further enquiry but does not, by itself, prove that particular transactions are fictitious or represent unaccounted money. A premise that exempt capital gains were claimed must also be supported by the return and computation. Interest on such an addition is consequential and must correspond to finally determined income.....