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The HC upheld ITAT's determination that land sold by assessee constituted agricultural land, rejecting AO's classification as barren land. Despite AO's contention that land was irrigated only through seasonal rains and wells with limited water retention capacity preventing crop cultivation, ITAT correctly relied on revenue records consistently classifying the land as agricultural, location 8 kms from nearest municipality, and documentary evidence including electricity subsidy receipts, soil test reports, agricultural income receipts, and ploughing expenses. The land in Kengayapalayam Village with population under 1600 was classified as "Punjai" wet land in patta records. Revenue authorities failed to produce contrary evidence to rebut assessee's documentation, instead relying on assumptions about commercial potential of the area for real-estate business purposes, which was insufficient to overcome established factual findings.
The HC upheld ITAT's determination that land sold by assessee constituted agricultural land, rejecting AO's classification as barren land. Despite AO's contention that land was irrigated only through seasonal rains and wells with limited water retention capacity preventing crop cultivation, ITAT correctly relied on revenue records consistently classifying the land as agricultural, location 8 kms from nearest municipality, and documentary evidence including electricity subsidy receipts, soil test reports, agricultural income receipts, and ploughing expenses. The land in Kengayapalayam Village with population under 1600 was classified as "Punjai" wet land in patta records. Revenue authorities failed to produce contrary evidence to rebut assessee's documentation, instead relying on assumptions about commercial potential of the area for real-estate business purposes, which was insufficient to overcome established factual findings.
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