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    <title>2026 (4) TMI 189 - ITAT DELHI</title>
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    <description>Compulsorily convertible debenture transactions were treated as genuine where the surrounding documents showed a real business project, bank borrowings, mortgage-backed funding by the assessee, and supporting subscription, transfer, sale and valuation records. In the absence of adverse material showing sham, collusion or circular money movement, the arrangement was not regarded as a colourable device merely because the debentures were subscribed at par or the sale generated a loss against capital gains. The test of human probabilities did not override the credible documentary evidence in a distress-driven commercial setting, and the short-term capital loss, along with the claimed set-off and carry forward, was upheld.</description>
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