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    <title>2015 (10) TMI 1275 - ITAT PANJI</title>
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    <description>The surplus from sale of land was not assessable as business income because the land remained agricultural in character: it was recorded as agricultural land in revenue records, lay beyond municipal limits, and was not shown to have been converted to non-agricultural use or stock-in-trade. Mere absence of actual cultivation during the holding period did not alter that character, and the transaction was not proved to be an adventure in the nature of trade. The surplus was therefore correctly treated as exempt agricultural income, and the addition was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=266000</link>
      <description>The surplus from sale of land was not assessable as business income because the land remained agricultural in character: it was recorded as agricultural land in revenue records, lay beyond municipal limits, and was not shown to have been converted to non-agricultural use or stock-in-trade. Mere absence of actual cultivation during the holding period did not alter that character, and the transaction was not proved to be an adventure in the nature of trade. The surplus was therefore correctly treated as exempt agricultural income, and the addition was deleted.</description>
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