Smt. Sarifabibi Mohmed Ibrahim v. CIT
What is Smt. Sarifabibi Mohmed Ibrahim v. CIT authority for?
The determinative test for whether land is agricultural land or a capital asset is its actual user for agricultural purposes, not merely ownership. An explicit intention to stop cultivation or convert the land to non-agricultural use can cause it to lose its agricultural character, making its sale proceeds chargeable to capital gains tax.
judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2026.
Also referred to as
Smt. Sarifabibi Mohmed Ibrahim v. CIT · Sarifabibi Mohmed Ibrahim · Section 2(14) · agricultural land definition · capital asset · actual user of land · intention to cultivate · capital gains tax on land sale · exemption for agricultural land · conversion of agricultural land · land character