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    <description>Consistent tax treatment was decisive: shares accepted as stock-in-trade in the preceding year could not be recharacterised merely because they were sold in the relevant year, so the resulting loss remained business loss rather than short-term capital loss. Likewise, interest earned by an assessee engaged in lending and advances continued to be assessed as business income where the same character had been accepted in earlier years and no change in facts or law was shown. The principle applied was consistency in assessment, and the Revenue could not depart from the settled position without cogent reasons.</description>
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