Capital Gain on Transfer of Agricultural Land and DRC Certificate

In my view, if the farmer is an Individual/HUF and the agricultural land was used for agricultural purposes for two years preceding acquisition, the amount received on sale of DRC/TDR issued against compulsory acquisition of land for DP Road can be claimed as exempt under section 10(37). The DRC/TDR is only a mode of compensation for compulsory acquisition. However, the claim must be supported by 7/12 extract, crop records, acquisition/DP road documents, DRC allotment letter and sale agreement. If section 10(37) is not accepted, an alternative argument may be examined that TDR/DRC had no ascertainable cost of acquisition, relying on Bombay High Court decision in Sambhaji Nagar Co-op. Hsg. Society, subject to facts.