Agricultural land character at transfer determines capital-gains treatment despite purchaser obtaining later non-agricultural-use permission.

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....Agricultural land retains its agricultural character at transfer where revenue records and receipts establish agricultural use, and the purchaser obtains non-agricultural-use permission only after sale; the resulting gain is not taxable as capital gains. Agricultural receipts recorded in books and supported by undisputed bills are not unexplained income merely because they were omitted from the return. Profit on sale of shares is assessable as capital gains rather than business income where the shareholder had no control over the company's management or business and the contrary treatment rests solely on an alleged controlling interest.....