Smoky quartz gets its brown from natural radiation acting on trace aluminium in the crystal, over geological time. That process can be reproduced in an afternoon with a gamma source, and a large fraction of the very dark, very even smoky quartz on the market has been.
Treated material is not fake — it is quartz, and the colour is stable — but it is worth a great deal less than a natural crystal of the same depth, and a seller who does not disclose it is not being straight with you. The tell is the evenness. Natural smoky colour is usually zoned: stronger towards the termination, patchy, sometimes in visible phantom layers where growth paused. Irradiated stone tends to a flat, uniform, slightly grey-brown tone right through the piece.
Very dark, almost black smoky quartz is called morion, and near-opaque examples are more often treated than not. If a crystal is uniformly the colour of dark beer from base to tip with no zoning at all, assume treatment and price it accordingly.
References and sizesCairngorm · Morion (near-opaque black)
Establish which of these you are holding before judging it. A genuine piece read against another reference's rules will look wrong when it is not.