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Manibhai Motibhai Patel vs Commissioner Of Income-Tax, Gujarat on 27 February, 1981

In the case of Manibhai Motibhai Patel Vs. CIT 131 ITR 120 (Guj.), the Hon'ble High Court held that in a case where the land was used for agricultural purposes right from the beginning, the sale of land for house construction and the persons of building projects in the vicinity of the land was not material. It was held that the lands were agricultural land at the time of sale and therefore, profit on the sale of land was completely immaterial.
Gujarat High Court Cites 15 - Cited by 11 - Full Document

Commissioner Of Income Tax Ii vs Shri Harjit Singh Sangha on 17 September, 2012

In CIT-I/, Chandigarh Vs. Harjit Singh Sangha (2003) 217 Taxman 201, the Punjab & Haryana High Court observed in a case where the assessee sold his agriculture land in small size plots and the Assessing Officer charged tax on the profit "the ITA No.6231/Del/2016 7 said asset being held by the assessee cannot be said to be a business asset and its sale in small plots of land to different purchaser is not a adventure in the nature of trade, in the absence of the assessee having floated the same or divided its land for the purpose other than agriculture land. Further for converting the use, prior permission is required from the authorities and in the absence of any permission being obtained by the assessee from PUDA authorities in respect of the land sold, merely because the land is sold in smaller plots to persons, who intended its residential use, does not change the nature of land sold in the hands of the assessee, and it's taxability."
Punjab-Haryana High Court Cites 2 - Cited by 7 - A K Mittal - Full Document

Sri M.S.Srinivasa Naicker vs The Income Tax Officer on 29 January, 2007

In the case of M.S. Srinivas Naicker V. ITO (2008) 169 Taxman 255 (Mad.), the Hon'ble High court of Madras observed that the chargeability of tax uls 45 arise only if on the date of sale, the land in question retained it character as a capital asset, which means, an asset which did not answer to the description of capital asset and which is an agricultural land falling within the definition of section 2(14) would automatically be outside of the section 45. What emerges from all these case laws is that once it is established that the land in question was held outside 8 kms from municipal limits or even within 8 kms but no notification had been it then even if the assessee divided the land into small plots and sold it, the the nature of the land did not change as far as the assessee was concerned and since it was not a capital asset, capital gains tax could not be charged on the same. Applying the logic of the said judgements, it is held that the computation of capital gains of Rs.10,59,411/- by the A.O. on the grounds that the same had been declared by the assessee in the return is not sustainable because the land was both outside 8 km of municipal limits and no notification had been issued for kotdwar plus there was evidence to indicate agricultural operation on the land.

The Commissoner Of Income Tax vs Shri Madhukumar N (Huf) on 28 March, 2012

In the case of CIT Vs. Madhukumar N (HUF) (2012) 208 Taxman 394 (Kar.) the Hon'ble High Court held that section 2(14)(iii)(b) of the Act covers the situation where the subject land was not only located within the distance of 8 Kms, from the local limits but also requires the fulfilment that the Central Govt. had issued a notification under this clause for the purpose of including the area upto 8 Kms. from the municipal limits, to render the land as a capital asset. It concluded that in the absence of a notification issued under clause (b) to section 2(14)(iii), the land could not be held to be a capital asset. In the instant case, the A. O. has admitted that no such notification has been issued for Kotdwar. Hence, the land could not be considered to be a capital asset in that sense. However, the A.O. has held that capital gain arose because the assessee was involved in the plotting and layout of the land.
Karnataka High Court Cites 0 - Cited by 23 - Full Document

Cit vs Smt. Sanjeeda Begum on 25 February, 2005

The Hon'ble Al1ahabad High court in ITA No.6231/Del/2016 6 the case of CIT Vs. Smt. Sanjeeda Begum (2006) 154 Taxaman 346 (All.) had occasion to consider a similar case. In that case the assessee sold part of the land measuring 2888 Sq. Yards during the Assessment Year in question to 12 different persons after dividing the lands into plots, each plot having an area of about 200 Sq. Yards and the colony having been named Shiv Vihar Colony. The assessee's claim that the land was agricultural land, was also situated outside the municipal limits and it was not covered by the Notification of the Govt. of India issued under section 2(14)(iii)(b) of the of the I. T. Act, 1961 and therefore, no capital gains were applicable. However, the Assessing Authority did not accept the plea as the land was under regulated area of Saharanpur for which the Addl. Disti. Magistrate had fixed a circle rate and it was situated near to Saharanpur City and was in the proximity of building and building sites. He took the view that agricultural land had been converted into non-agricultural land before the date of agreement to sell and therefore the provisions regarding capital gains were attracted. In appeal the AAC, Dehradun accepted the plea of the assessee after he came to the conclusion that the land was not within 8 kms of municipal limits and were agricultural lands. The ITAT upheld the conclusion drawn by the AAC. The matter came before the Hon'ble High Court which held that "on the findings recorded by the Tribunal that the land was agricultural land and stood beyond 8 kms of the municipal limits of Saharanpur, it was not included in the definition of capital assets as given in section 2(14)(iii) of the Act. Thus, there is no infirmity in the order of the Tribunal".
Allahabad High Court Cites 2 - Cited by 12 - Full Document

Hyderabad Hi-Tech Park Private ... vs Ito, Ward-2(2), Hyderabad, Hyderabad on 21 December, 2016

Further in the case of Hamiks Park Pvt. Ltd. Vs. Ward-2(2), Hyderabad (2014) 41 Taxman.com 109 (HYD- Tribe), the Hon'ble ITA T, while examining the case of assessee who was engaged in agricultural operation on land classified as agricultural land in revenue records and transferred such land on as is and where is basis to a developer held that since the land was situated In rural area outside the municipal limits, and since agricultural operations were being carried out by the assessee on the said land and since it was classified as agricultural land in revenue records, the said land did not come within the purview of capital asset uls 2(14) of the I. T. Act, 1961 and, therefore, the profit earned on the sale of land was agricultural income of the assessee liable to be exempt from tax.
Income Tax Appellate Tribunal - Hyderabad Cites 9 - Cited by 3 - Full Document
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