The assessee sold a plot of land and claimed that it constituted agricultural land, and therefore was not taxable as capital gains. The Court noted that all the authorities had concurrently held that the land was not used for agricultural purposes, and consequently, the income arising from the sale of the land was chargeable to tax. It was observed that Form 7/12 (revenue records) is a relevant piece of evidence on which an assessee may legitimately rely; however, it is not conclusive. The authorities found that the assessee had not undertaken any agricultural activity on the land and had failed to make full and proper disclosure of agricultural income, having stated that the net agricultural income, after excluding expenses, was negligible. The authorities further relied on the clauses in the sale agreement, which indicated that the land was sold for development purposes, to be converted into plots and sold to third parties. Consideration was also given to the proximity of the land to the metropolitan cities of Mumbai and Thane, as well as the substantial expenditure incurred for the development of the land. The assessee was found to have made contradictory and inconsistent statements regarding the agricultural use of the property. The Court held that the assessee had failed to demonstrate any perversity in the authorities’ findings. Since all relevant material and contentions had been duly considered by the lower authorities, there was no reason to interfere with the concurrent findings of fact, and no question of law, much less a substantial question of law, arose for consideration. SLP dismissed.  (AY.  2011-12)