Urban land tax liability turned on factual land use, and the assessment was upheld after inspection showed non-agricultural use.

Land assessed as vacant in part and as a resort area with guest houses, restaurants and shops in part was treated as urban land, not agricultural land, for liability under the Tamil Nadu Urban Land Tax Act, 1966. The authorities relied on notice, inspection and user of the property to determine its character, and the petitioner's reliance on earlier agricultural income-tax treatment was rejected as relating to different periods. Since the original and revisional authorities had already carried out the factual exercise of measuring the property and ascertaining its use, interference under Article 226 was not warranted on a mere reappreciation of facts. The challenge to the assessment therefore failed.

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Issues: Whether the lands assessed by the authorities were agricultural lands exempt from urban land tax, or urban lands capable of use as house sites and therefore liable to tax under the Tamil Nadu Urban Land Tax Act, 1966.

Analysis: The assessment was made after notice and inspection of the lands. The revisional authority relied on the inspection reports and recorded that some survey numbers were vacant, while others were used as a resort area with recreational facilities, guest houses, restaurants and shops. The petitioner's plea that the lands were agricultural in character was rejected on facts, and the earlier agricultural income-tax assessment was treated as relating to different periods. The Court held that the factual exercise of measuring the property and ascertaining its user had already been carried out by the original and revisional authorities, and that interference under Article 226 was not warranted on such reappreciation of facts.

Conclusion: The lands were held to be urban lands liable to urban land tax, and the challenge to the assessment failed.

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