There are two different possibilities.
"Brushing" involves creating fake accounts to place phony orders for expensive widgets -- not necessarily on eBay, since eBay would take a large percentage of the "fake" transaction, but possibly on another site. The scammer orders a cheap plastic part or some seeds from a fulfillment service for a few cents to generate tracking that shows delivery to "prove" that delivery has taken place, even though the order itself is otherwise entirely phony. The seller can quickly create the appearance that the seller is doing lots of successful business selling expensive widgets. Because the seller is on both sides of the same transaction, the seller can be sure to receive glowing positive feedback.
"Fake tracking" on eBay involves an actual buyer unknowingly placing an order from a scammer. The scammer ships a cheap plastic part from a fulfillment service for a few cents to generate tracking that shows delivery to the buyer's area, though not necessarily to the actual buyer's address. Perhaps a business or a church in the same zip code. The tracking with delivery makes it difficult for the actual buyer to win an "item not received" or "not as described" case with eBay through the automatic process, making it more likely the scammer will be able to disappear with the funds.
