agricultural purpose with relaxed conditions, unless collector grant Sanad u/s 32 of Goa Land Revenue Code, 1968 ”. Further, in Goa, in terms of section 32 of the Goa Land Revenue Code, 1968, it is mandatory for any person who wishes to use his non-agricultural land for other non-agricultural purpose, to obtain concession Sanad/permission from collector. He pointed out that first of all the land purchased by the applicant no.1 is falling under settlement area, as there are several houses in the said entire property and what the applicant no.1 wanted to do was to set up a Hotel project and therefore in terms of Goa Land Revenue Code, 1968. Therefore, the permission/Sanad from Collector was mandatory, even for this settlement land. Therefore, only because the applicant no.1 had applied for conversion does not make applicant‟s land of Agricultural category. Accordingly, she asserted that in terms of section 13(2) of FEMA, 1999, the immovable property of the applicant no.1 cannot be confiscated to the Government of Goa.Ld. Special Director ought to have considered that, in terms of “Property” u/s 13(2) of FEMA, 1999 does not cover “immovable property” in the instant case.Ld. Counsel for the appellant further contended that Ld. Special Director failed to consider that the money utilized for purchase of the “immovable property” bearing survey no. 313/1 had come to India through proper route and therefore was not purchased in contravention of FEMA, 1999, or any regulations thereunder and therefore it cannot be termed as “Property” as defined u/s 13(2) of FEMA,