• TDR sold in the year 2012. Capital Gain tax?

Our agricultural property was acquired for road widening in the year 2005. In 2012, we applied for TDR from the BBMP (Bangalore) and in the same year, a TDR certificate was issued to us. In Nov-2012, we sold the same to a third party for a monetary value. 

Details about the agriculture property. In 2005, it was more than 8kms from Bangalore urban city limits. The crop info for the years 2003-2005 has Nilgiri trees mentioned in the RTC. In 2012, this agriculture property was within 8 kms from the Bangalore urban city limits. 

We were under the assumption that compulsory acquisition of Agriculture land and any compensation received will has tax exemption. Therefore we did not pay any capital gain for the money received against sale of TDR for the FY 2012-13. 

on [deleted], we have received a notice under Section 148 which states:
"Notice Under Section 148 Of The Income Tax Act, 1961
Whereas I have reasons to believe that your Income chargeable to Tax for the Assessment Year
2013-14 has escaped Assessment within the meaning of section 147 of the Income Tax Act, 1961.
I, therefore, propose to assess/ re-assess the income/ loss for the said Assessment Year and I hereby
require you to deliver to me within 15 days from the service of this notice, a return in the prescribed
form for the said Assessment Year.
This notice is being issued after obtaining the necessary satisfaction of the PCIT, Bengaluru-1"

So i have 3 questions.

1. Does the above notice have any time limit? Is this notice maintainable?
2. Does sale of TDR attract capital gain? I have read some recent articles that say "At the outset, most of the Judicial Fora have held that surrender of land for the acquisition of TDR would be completely exempt, because in case of acquisition of TDR, the land which is transferred is different and TDR right received is different, for which there is no cost of acquisition and therefore, when the TDRs are sold, there is no capital gains liability." By this logic, can our case also not attract capital gain tax?
3. If sale of TDR is taxable, can we then claim exemptions on the grounds that it was Agriculture land? 



Thank you