Capital gains tax Valuation for TDR

TDR if received against surrendered of a portion of land , the cost of land surrendered will be cost of the TDR. Therefore, in my view TDR surrender will be subject to either short term capital gain or Long Term Capital Gains depending upon the holding period of the land. If the land is held for less than 3 years then it will attract short term capital gains tax and it is held for more than 3 years then it will attract Long Term Capital Gains Tax.