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    <description>Surplus from land sales was treated as taxable business income because rapid sales, recorded conversion to non-agricultural use, absence of genuine agricultural operations, and regular profit-oriented transactions supported the finding that the land was non-agricultural and outside the agricultural-land exclusion. Rejection of books of account was sustained because purchases were found non-genuine, no proper stock register was maintained, and opening and closing stock could not be verified. The resulting trading addition was supported by the record. Agricultural character of land and reliability of accounts are primarily factual matters; concurrent findings are not disturbed unless perverse or unsupported by evidence.</description>
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