Is it required to file return in this case?

Hello!
Asking on behalf of a frnd - His yearly income is within the basic exemption (less than 2 Lac)but he has sold an agriculture land which falls under CTR for Capital Exemptionbecause it is 12 km away from the milits of Municipal Corporation!
He wants to ask that whether should he file i.tax return in this case or not? Because he has been told that there is no need to file return if your income is not taxable..