Penny-stock gains face scrutiny where extraordinary prices, operator records and layered funding undermine transaction genuineness.

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....Penny-stock long-term capital-gain claims may fail despite demat, exchange, banking and securities-transaction-tax records where abnormal price movement, operator material and layered purchaser funding establish accommodation entries under the test of human probabilities; related commission additions may consequently stand. Exempt-income expenditure disallowance requires examination of all exempt income, including claimed long-term gains, and may require recomputation. A loose-paper entry cannot be added to a person not named or supported by material, though it may be considered in the attributable family member's assessment. For unsecured loans, established identity alone does not prove creditworthiness or genuineness. Confirmed foreign-account sources can defeat additions absent contrary material. Concealment penalties are invalid where notice does not specify the applicable charge.....