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HC upheld the tax authorities' determination that the disputed land was not agricultural land under Section 2(14)(iii) of the Income Tax Act, making gains from its sale taxable as capital gains. Despite 7/12 land revenue extracts showing agricultural status, three authorities consistently found no actual agricultural use by the assessee after evaluating all evidence. The court declined to reassess evidence sufficiency, noting its limited jurisdiction under Section 260A. The authorities' factual findings were deemed adequately supported by record evidence, distinguishing this case from Shri Shankar Dalal where arbitrary land classification was overturned. The appeal was dismissed, confirming the land's non-agricultural status for tax purposes.
HC upheld the tax authorities' determination that the disputed land was not agricultural land under Section 2(14)(iii) of the Income Tax Act, making gains from its sale taxable as capital gains. Despite 7/12 land revenue extracts showing agricultural status, three authorities consistently found no actual agricultural use by the assessee after evaluating all evidence. The court declined to reassess evidence sufficiency, noting its limited jurisdiction under Section 260A. The authorities' factual findings were deemed adequately supported by record evidence, distinguishing this case from Shri Shankar Dalal where arbitrary land classification was overturned. The appeal was dismissed, confirming the land's non-agricultural status for tax purposes.
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