Dismissing the appeal the Tribunal held that it was evident from the findings of the Commissioner (Appeals) that in view of information provided by the Investigation Wing and the recommendations of the Special Investigation Team on black money, the assessee was required to prove her claim to exemption. After considering her reply, the Commissioner (Appeals) held that the assessee had manipulated the sale of shares within a short span of time in collusion with brokers in order to earn tax-free exempt long-term capital gains on the sale of shares under section 10(38) of the Act. The assessee had also not placed on record any material to prove that the claim of exemption under section 10(38) was genuine. Further, the action of the assessee was pre-motivated and deliberate conduct done for converting unaccounted money under the guise of long-term share transactions and that too without paying requisite tax thereon. This clearly amounted to tax evasion. It was beyond preponderance of probabilities that the fantastic sale price of little known shares, i. e., M Ltd., without any economic or financial basis would increase from Rs. 5 to Rs. 282 per share, 56 times in a span of 28 months. There was no doubt that the capital gains were manipulated and bogus and done to claim exemption under section 10(38) of the Act.  Order of CIT(A) is affirmed. Relied  PCIT v. Swati Bajaj (2022) 446 ITR 56 (Cal)(HC)  (AY.  2015-16)