Agricultural land classification remains a factual issue, and concurrent findings stand absent perversity or legal error.

An appeal under Section 260A cannot succeed unless a substantial question of law arises; where the Tribunal has reached a reasoned factual finding that land is agricultural in character, based on revenue records, land revenue payment, actual agricultural use and surrounding circumstances, that finding will not be disturbed. The nature of a particular parcel of land is essentially a question of fact, assessed on the cumulative evidence. Concurrent factual findings cannot be reappreciated in the absence of perversity, disregard of material evidence, or a legal error affecting the decision. No such error was shown, so no substantial question of law arose and the agricultural character finding stood.

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Issues: Whether the appeal under Section 260A of the Income-tax Act, 1961 involved any substantial question of law so as to permit interference with the Tribunal's finding that the land sold was agricultural land.

Analysis: The Tribunal had recorded a reasoned finding, on the basis of the revenue records, land revenue payment, actual and ordinary use of the land for agricultural purposes, and the surrounding factual circumstances, that the land was agricultural in character. The question whether a particular land is agricultural land is essentially one of fact, to be answered on a cumulative evaluation of all relevant circumstances. In an appeal under Section 260A, the High Court can interfere only if a substantial question of law arises. Concurrent factual findings cannot be reappreciated in the absence of perversity, ignorance of material evidence, or a legal error affecting the decision. No such error was shown here.

Conclusion: No substantial question of law arose, and the factual finding that the land was agricultural land was not liable to be disturbed.

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