( 1 ) REVENUE is before us raising the following questions of law;

a. Whether the tribunal was correct in holding that the value of properties held by the assessee at Adugodi and Koramangala is not chargeable to wealth tax as the same are not urban land but land with super structure and cannot form part of the wealth as defined under Section 2 (e) (a) of the Act.

b. Whether the properties of the assessee cannot be brought to Wealth Tax assessment?

( 2 ) THE facts of the case are as under : assessee is assessed in the status of Hindu undivided Family. During assessment year 2000-01, assessee owned a property at Sy. Nps. 67/2, 67/3, 67/4 and 67/5 at Adugodi village and portion of Sy. No. 151 at koramangala Village of Begur Hobli of Bangalore South Taluk. This property was given to M/s. Prestige Estates Properties Private ltd. , Bangalore under various agreements for construction of residential flats. The development agreement was considered by the assessing officer in the course of assessment proceedings. Assessee claimed that it had retained ownership of the land until flats are fully constructed and possession of the assessee's share were handed over to it. The develo