Taxability of rural agricultural land

rural agricultural land is not capital asset hence no capital gain arise but also section 10 does not exempt it either and gain on transfer of rural agricultural land meets the definition of income as well..as in my view it should be treated as income from other source because income from other source is a residual head any income which does not find it place in any of four heads should be included in income from other source.now i want you people to rectify me but with proper reference if i am wrong....because i am really confused how everyone says it is not taxable based on it not capital asset