JUDGMENT :

1. Heard learned Counsel appearing for the parties.

2. By the consent of the parties both the Writ Petitions being WPA No. 4305 of 2022 & WPA No. 4308 of 2022 are heard together and disposed of by this common judgment in view of similarity of facts and points of law involve in both the Writ Petitions and only difference is the year of assessment and both these Writ Petitions arise out of the impugned orders dated 26th March, 2021 and 18th February, 2021 respectively passed by the Appellate authority confirming the assessment orders dated 19th August, 2013 relating to assessment years 2009-10 and 2007-08 respectively passed by the Agricultural Income Tax Officer under Section 5 (3) of the Bengal Agricultural Income Tax Act, 1944 and rectification order dated 8th August, 2016.

3. For the sake of convenience WPA No. 4305 of 2022 is taken up and discussed.

4. In this Writ Petition, Petitioner has challenged the impugned order of the first Appellate authority under Bengal Agricultural Income Tax Act, 1944, dated 26th March, 2022, passed on the Appeal of the petitioner filed under Section 34 (1) of the Bengal Agricultural Income Tax Act, 1944 confirming the assessment order dated