Held, that the loss incurred on the sale of shares on a stock exchange platform, where securities transaction tax is  paid, is  eligible to be set off against the long-term capital gains earned by the assessee from sale of unlisted shares. The AO is directed to set off the loss against the long-term capital gains.  Relied on Royal Calcutta Turf Club v.CIT(1983) 144 ITR 709 (Cal)(HC), wherein the Court held that when the entire source is not excluded from the charging section and only a special type of the income is excluded then the interpretation of law has to be made strictly and cannot be deemed to include the any other income or loss resulting or falling within the same source.  (AY.2014-15)