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    <title>2026 (4) TMI 1623 - ITAT AHMEDABAD</title>
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    <description>Gains from genuine, delivery-based sale of listed shares were treated as capital gains because the transactions were supported by demat records, contract notes and banking channels, and the shares were consistently recorded as investments in the books. Long-term gains on shares held for more than 12 months were covered by CBDT Circular No. 6/2016, and the absence of bogus or sham transactions supported capital treatment. For short-term gains, the lack of trading infrastructure, systematic trading indicators or organised business activity showed an investment intent, and borrowed funds alone did not convert the transactions into business income. The addition was therefore unsustainable and the Revenue&#039;s challenge failed.</description>
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