Court : Income Tax Appellate Tribunal ITAT Cochin
Reported in : (1984)9ITD100(Coch.)
..... " there is no dispute by either party that the statement of facts contained in the above paragraph represents the true state of affairs.in addition, the assessee had in the course of the reassessment proceedings, filed before the iac a letter dated 1-3-1966 by the officer of the development department of the rubber board to the secretary of the agricultural refining corporation, bombay, a copy of which has been endorsed to the assessee. ..... this letter contained the report about the feasibility of extending the rubber plantation to an area of 769.94 acres and the requirement of finance for this purpose.the assessee had also made certain submissions before the ito in the form of two letters dated 19-1-1978 and 21-6-1978 when the ito was seized of these assessment proceedings by reason of the order of the tribunal under section 254(2).a statement described as acreage statement detailing the total acreage in the possession of the assessee, the area planted, the area covered by buildings, roads, etc. ..... the contention was that in the absence of such actual conversion of the forest land into agricultural land, the land would not assume the character of agricultural land so as to be excluded from the definition of capital asset contained in section 2 of the act.6. .....
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