Shares Sale Classified as Capital Gains Due to Repurchase Agreement, Not Business Income; Intent to Trade Absent.

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....Gain on sale of shares - capital gains or business income - buy back of shares by the borrowers - the object of trading in shares was lacking in as much as the financial collaboration agreement itself prescribed that the shares shall be bought back by the private promoter after a specified period at a defined consideration - realization from such investments was Capital gains....