The assessee sold land and claimed exemption under section 2(14) by contending that it was agricultural land and thus excluded from the definition of a capital asset. The Assessing Officer and the Tribunal rejected the claim as the assessee failed to produce cogent evidence to establish its agricultural character. The description in the revenue records contradicted the Village Officer’s certificate by identifying the land as ‘Purayidam’ (dry land suitable for construction). No supporting evidence regarding wages paid, fertilizer invoices, or irrigation was produced to substantiate agricultural operations. The High Court held that no substantial question of law arose, and the Hon’ble Supreme Court dismissed the Special Leave Petition, finding no grounds for interference. (AY. 2006-07)