Tax-motivated capital loss remains allowable where share transactions are genuine and lack evidence of an artificial arrangement.

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....Genuine share transactions supported by banking records and transfer documents cannot be disregarded merely because they generate a tax loss. The discussion identifies that no adverse material established an artificial or pre-conceived arrangement, and the sale price exceeded the price at which another related purchaser had acquired the shares. On these facts, the short-term capital loss from sale of unlisted shares to a spouse was not treated as a colourable device, and its disallowance was deleted.....