Assessee sold a land and gain arising from sale was claimed to be exempt on ground that said land being an agricultural land was not a capital asset within meaning of S. 2(14)(iii) of the Act  on the basis of certificate issued by Tehsildar  showing that land sold was located 20 km. away from limit of Chennai Municipal Corporation. AO allowed the exemption. The assessment was reopened on basis of information received in form of a communication from DDIT (Inv.) which stated that area of Chennai Metropolitan region was much larger than what was stated by Tehsildar in his report and land sold by assessees was situated at about 3 kms. from Chennai Metropolitan area, thus, same was not rural agricultural land. On appeal the Tribunal held that location of land from local limits of Chennai Municipal Corporation was relevant to decide as to whether said land was an agricultural land within meaning of clause (iii) of S. 2(14) and distance of land from Chennai Metropolitan area was not relevant in this context. Accordingly the reassessment is held to be bad in law. (AY.2011-12)