Heard the learned counsel appearing for the petitioner and the learned Government Advocate appearing for the respondents.

2. It has been stated by the petitioner that he is the owner of the property in S.No.392 of Kuniamuthur, Coimbatore, having obtained an extent of 74 cents in a partition suit, in O.S.No.234 of 1975, on the file of the Sub Court, Coimbatore. The said land has been an agricultural land both at the time of its partition and even thereafter. Since agricultural lands are excluded from the levy of Urban Land Tax, the land held by the petitioner was not subject to the assessment and levy of Urban Land Tax. While so, the second respondent had passed an order of assessment, for an extent of 11 grounds and 1080 sq.ft., vide ULT.Case No.26/KMR/1391, dated 20.93. The petitioner had not been served with the notice under Form 4(C), or the assessment order. However, the third respondent had made a demand, on 11. 98, directing the petitioner to pay tax from fasli 1398 to 1408. Therefore, the petitioner had preferred a revision, under Section 30 of the Tamil Nadu Urban Land Tax Act, before the first respondent. The first respondent had granted stay of the collection