Dismissing the appeal of the assessee the Court held that, there was no agricultural activities in preceding two years of transfer. The Inspector’s report had not only reflected on the land in the year 2011, but on the spot inquiries to ascertain whether the land was being used for agricultural purposes prior to sale of the land in December 2008. The Tribunal had given reasonable and cogent reasons for the findings on facts.  Accordingly the denial of exemption was up held. (AY. 2009 -10)