JUDGMENT R.S. Pathak, J. - The petitioner is a private limited company carrying on agricultural and farming activity. It was assessed for the assessment years 1365 Fasli and 1367 fasli by the Sub-Divisional Officer, Varanasi. In the assessment proceedings, the petitioner pointed out that a certain area had been declared as reserved forest by the Government and was not in the possession of the petitioner and, therefore, it should be excluded from its land holding. This contention was accepted by the Sub-Divisional Officer and after examining the records he determined that the area declared as reserved forest could not be included in the land holding of the petitioner. Against the two assessment orders, the State of U.P. filed revision applications under Sec. 12 of the U.P. Large Land Holdings Tax Act. The Board of Revenue allowed the revision applications and holding that "in excluding the land in dispute the Assessing Authority exercised jurisdiction not vested in it by law and acted in the exercise of its jurisdiction illegally and with substantial irregularity," quashed the orders of the Assessing Authority and remanded the case for reassessment after including the valuation of the holdings in dispute. The petitioner, aggrieved by these orders, has filed the instant and the connected petition for certiorari. 2. The only contention raised on behalf of the petitioner before me is that the Board of Revenue is confined to the jurisdiction conferred by Sec. 12 of the Act and is not empowered to interfere with the assessment of the Assessing Authority on its merits. It is pointed out that the jurisdiction of the Board of Revenue is confined to cases where the Assessing Authority has exercised jurisdiction not vested in it by law or to have acted in the exercise of its jurisdiction illegally or with substantial irregularity. What the Board of Revenue has done in the instant cases, it is said, is to enter into the merits of the assessment and hold that the actual valuation of the land holding determined by the Assessing Authority was erroneous because he had taken a wrong view in computing the land holding of the petitioner. There is force in this contention. 3. Sec. 3 of the Act imposes a charge on the annual value of each land holding, and the charge is called the holding tax. There is force in this contention. 3. Sec. 3 of the Act imposes a charge on the annual value of each land holding, and the charge is called the holding tax. "Land holding" is defined by Sec. 4, and "annual value" is defined by Sec. 5. Both these provisions are definition provisions. The power of assessment is conferred in Chapter III. Sec. 6 indicates who is the Assessing Authority and Secs. 7, 8 and 9 set out the procedure for assessment. Sec. 10 requires a notice of demand to be served on the assessee consequent upon the assessment. The Jurisdiction of the Assessing Authority for the purpose of assessment must, therefore, be found in Secs. 7, 8 and 9. Sec. 7 requires the Collector to publish a notice requiring every land-holder who is liable to the holding tax to furnish to the Assessing Authority a return of all land held by him. Pursuant to that notice a land-holder is required to file a return. Sub-Sec. (1) of Sec. 8 provides that the Assessing Authority, if satisfied that the return made under Sec. 7 is correct and complete, shall determine the annual value of the land holding and assess the holding tax chargeable thereon on the basis of the return. Where the Assessing Authority has reason to believe that the return made under Sec. 8(1) is incorrect or incomplete, sub-Sec. (2) of Sec. 8 provides that he shall require the land-holder who made the return either to attend before him or to produce or cause to be produced evidence in support of the return. The Assessing Authority after considering the evidence produced before him is empowered by sub-Sec. (3) to determine the annual value of the land holding and assess the holding tax chargeable thereon. If no return is filed by the assessee under Sec. 7 or he fails to comply with the provisions of sub-Sec. (2) or sub-Sec. (3) the Assessing Authority has jurisdiction to make an assessment to the best of his judgment. The scope of the Assessing Authoritys jurisdiction for the purpose of assessment is set out by Sec. 8 and in the exercise of that jurisdiction the assessing Authority is required to determine the annual value of the land holding and assess the holding tax chargeable thereon. The scope of the Assessing Authoritys jurisdiction for the purpose of assessment is set out by Sec. 8 and in the exercise of that jurisdiction the assessing Authority is required to determine the annual value of the land holding and assess the holding tax chargeable thereon. For the purpose of determining the annual value of the land holding the Assessing Authority must first determine the land holding of the assessee by reference to Sec. 4 and then compute the annual value of the land holding by reference to Sec. 5. Having determined the annual value of the land holding he must then assess the holding tax chargeable thereon at the rates specified in the Schedule to the Act. The determination of the annual value of the land holding is a matter which falls within the jurisdiction of the Assessing Authority. In the exercise of that jurisdiction the Assessing Authority may make an error in the determination contemplated by the statute, but such error cannot, in my opinion, be said to affect his jurisdiction. So long as he continues to travel within the scope of his jurisdiction detailed by Sec. 8, the determination made by him cannot be assailed on the ground that it suffers from a jurisdiction defect. The determination may be erroneous on its merits. The Assessing Authority may, for the purpose of determining the annual value of the land holding, wrongly determine the extent of the land holding of the assessee or may wrongly determine the annual value of the land holding. These are errors committed by him while exercising his jurisdiction. They cannot be corrected as jurisdictional errors by the exercise of the revisional power by the Board of Revenue under Sec. 12. The Assessing Authority cannot also be said to have acted illegally or with substantial irregularity in the exercise of its jurisdiction unless it commits material errors of procedure which vitiate the determination made by it or ignores statutory provisions material to the making of that determination. In the instant case the Assessing Authority found that the petitioners contention that the area in question had been declared a reserve forest and was not in the possession of the assessee should be accepted and he came to that conclusion upon examining the papers before him. In the instant case the Assessing Authority found that the petitioners contention that the area in question had been declared a reserve forest and was not in the possession of the assessee should be accepted and he came to that conclusion upon examining the papers before him. It has not been shown to me that the view taken by the Assessing Authority falls within the class of cases where it can be said that it exercised jurisdiction not vested in it by law or acted in the exercise of its jurisdiction with illegally or material in regularity. 4. The language of Sec. 12 defining the jurisdiction of the Board of Revenue is very different from the revisional power conferred upon similar authorities under other statutes. Under the Income Tax Act Secs. 33A and 33B conifer the power of revision upon the Commissioner, and there the Commissioner is empowered to examine the record of any proceeding under that Act and to revise the order made by any authority subordinate to him. There is no limitation upon the scope of his jurisdiction. All that he has to see is that the order of the subordinate authority is erroneous. Under the U.P. Sales Tax Act Sec. 10 confers the power of revision upon a Revising Authority, and the jurisdiction of the Revising Authority extends to the examination of the record of any Assessing or Appellate Authority for the purpose of determining the legality or propriety of any order made by that Authority. Sec. 22 of the U.P. Agricultural Income Tax Act also confers wide powers upon the Revision Board to revise orders of authorities subordinate to it. It provides that the Board may call for the record of any proceeding pending before an authority subordinate to it and pass such orders as it thinks fit. It is apparent that the revisional power conferred by Sec. 12 of the U.P. Large Land Holdings Tax Act is extremely Limited when compared with the corresponding provisions in these other statutes. I am of opinion that the order of the Board of Revenue allowing the revision applications filed by the State exceeded the jurisdiction conferred upon the Board by Sec. 12 of the Act and must, therefore, be quashed. 5. The petition is allowed. A writ in the nature of certiorari shall issue quashing the order of the Board of Revenue. I am of opinion that the order of the Board of Revenue allowing the revision applications filed by the State exceeded the jurisdiction conferred upon the Board by Sec. 12 of the Act and must, therefore, be quashed. 5. The petition is allowed. A writ in the nature of certiorari shall issue quashing the order of the Board of Revenue. The petitioner is entitled to its costs. Petition allowed.