Judgment :- Y. VENKATACHALAM, J. In all these writs, as the, subject-matter involved and also the parties to the writs are one and the same, all these writ petitions were taken up together and are disposed of by this common order with the consent of all the parties concerned. Invoking article 226 of the Constitution of India, the petitioner herein has filed the present writ petitions seeking for a writ of certiorari to call for the records relating to the proceedings of the second respondent made in G.I.R. No. 72-R/MDS of 1987-88, etc., dated November 11, 1991, and confirmed by the orders of the first respondent bearing No. R.P. Nos. 6 to 9 of 1992, dated February 21, 1992, and to quash the same. In support of the writ petitions, the petitioner herein has filed separate affidavits narrating all the facts and circumstances that forced him to file the present writ petition and requested this court to allow the writ petitions as prayed for. Per contra, on behalf of the respondents, a counter affidavit has been filed rebutting all the material allegations levelled against them one after the other and ultimately they have requested this court to dismiss the writ petitions for want of merit. Heard the arguments advanced by learned counsel appearing for the respective parties. I have perused the contents of the affidavits and the counter affidavits together with all the other relevant material documents available on records in the form of typed set of papers. I have also taken into consideration the various points raised by learned counsel appearing for the respective parties during the course of their arguments. In the Above facts and circumstances of the case, the only point that arises for consideration in these cases is, as to whether there are any valid grounds to allow these writ petitions or notThe brief facts of the case of the petitioner as seen from the affidavits are as follows : The petitioner herein and three others are owners of 126.87 ordinary acres in Anoor Village, Chennai, MGR District. They cultivate casuarina in the said land and they are duly assessed under the Tamil Nadu Agricultural Income-tax Act 1955, (hereinafter called "the Act"). They cultivate casuarina in the said land and they are duly assessed under the Tamil Nadu Agricultural Income-tax Act 1955, (hereinafter called "the Act"). The said land falls within the definition of section 2(vv)(xii)(B) of the Act and therefore the said lands were rightly treated as ordinary acres and were duly categorised under the ratio 3 : 1, i.e., three ordinary acres into one standard acre. The petitioner has been duly paying the income-tax without any default. But the second respondent issued notice dated August 4, 1991, seeking to reopen the assessment under section, 65A(3) of the Act, treating all the lands as standard acres, under the ratio of, 1 : 1 as per section 2(vv)(xii) of the Act. He has no juridiction at all to bring the petitioner's land under, section 2(vv)(xii) of the Act. The said provision, is applicable only to one acre, of tope other than coconut tope. Thus it is very clear that the petitioner's land falls outside section 2(y) and, therefore, he cannot be categorised under section 2(vv)(xii) of the Act. Secondly, the said lands were in the name of the petitioner's mother, Mrs. Saraswathi Ammal. She died in the year 1985. After her demise the said lands equally devolved on the petitioner and her eldest son and elder daughter and the heirs of the younger daughter. The second respondent not only failed to exempt the first 20.00 std. acres as per the Act. Further, he could not make objection before the second respondent within time due to unavoidable circumstances. The second respondent without applying his mind, mechanically passed orders in cyclostyled papers. Other persons similarly situated, made objections before the second respondent. But he had mechanically rejected all those valid objections and passed orders in the very same cyclostyled papers. Thus it clearly shows that he has predetermined the issues and passed illegal and invalid orders. Aggrieved against the said orders of the second respondent, the petitioner preferred revision under section 34 of the Act before the first respondent. Since the second respondent was proceeding against the petitioner to recover the balance amount of income-tax on the basis of the illegal order dated November 11, 1991, the petitioner prayed for an order of interim stay, staying the order of the second respondent. The first respondent without appreciating the correct legal position rejected the stay petition filed by the petitioner. Since the second respondent was proceeding against the petitioner to recover the balance amount of income-tax on the basis of the illegal order dated November 11, 1991, the petitioner prayed for an order of interim stay, staying the order of the second respondent. The first respondent without appreciating the correct legal position rejected the stay petition filed by the petitioner. Thereupon the petitioner preferred W.P. No. 506 of 1992 before this court challenging the orders of the first respondent. The said writ petition is pending. On January 31, 1992, the first respondent was pleased to take up the revision for hearing. During the course of hearing, the first respondent strongly relied on the circular bearing No. R.C. No. 17990/90/G2. dated November 22, 1990, issued by the third respondent and informed counsel for the petitioner, who appeared before him, that the revised assessment orders are being passed only on the basis of the abovesaid circular. Counsel for the petitioner herein had rightly pointed out that the circular issued by the third respondent cannot be in conflict with the provisions of enactment and placed a copy of the judgment of this court reported in 1991 LW 697 . The first respondent has rejected the appeals by his order dated February 21, 1992. He did not mention anything about the said circular knowing fully well that it is in conflict with the provisions of the enactment. The act of the first respondent is improper and contrary to law. Having relied on the circular issued by the third respondent, he ought to have referred to the same in the order rejecting the appeal. He did not mention anything about the said circular knowing fully well that it is in conflict with the provisions of the enactment. The act of the first respondent is improper and contrary to law. Having relied on the circular issued by the third respondent, he ought to have referred to the same in the order rejecting the appeal. According to the petitioner, the revision under section 54 of the Act before the High Court is not available to him since the order of the first respondent is not prejudicial to him and it is only a confirmatory order and that, therefore, he has no other adequate or alternative remedy except to approach this court by way of these writ petitionsThe impugned orders in these writ petitions are challenged by the petitioner herein on the grounds that the order of the first and the second respondents are illegal and contrary to law, that the respondents failed to see that they have no jurisdiction at all to bring the petitioners' land under section 2(vv)(xii) of the Act, that the respondents failed to see that the "TOPE" under section 2(y) means any land containing large groups of fruit trees or valuable timber trees, whether growing spontaneously or grown artificially and included orchards and that, therefore, by no stretch of imagination the casuarina tree can be said to be a valuable tree. Further, according to the petitioners, the respondents failed to see that in their own rule 7A of the Tamil Nadu Agricultural Income-tax Rules, 1955, the casuarina is & classified as fuel plantation. According to the petitioner, the first respondent failed to see that the second respondent has not served notice on the other co-owners of the land in question, And thus the orders of the respondents are violative of the principles of natural justice and fair play. It is also their case that the first respondent erred in relying on circular No. R.C. 17990/90/G2, dated November 22, 1990, issued by the third respondent. He having relied on the said circular should have honestly referred the same in the order rejecting the appeal. It is also their case that the first respondent erred in relying on circular No. R.C. 17990/90/G2, dated November 22, 1990, issued by the third respondent. He having relied on the said circular should have honestly referred the same in the order rejecting the appeal. In the counter affidavit it is contended by the respondents that the petitioner and three others are owners of 126.57 ordinary acres of land in the Anoor Village and they were assessed for the assessment years 1987-88, 1988-89, 1989-90 and 1990-91 an extent of 126.57 ordinary acres equivalent to 79.93 standard acres. During the verification of the assessment records it was noticed that the Casuarina cultivated in an extent of 69.96 acres has been categorised under the ratio 3 : 1 as against 1 : 1 as per the provisions of section 2(vv)(xii) of the Tamil Nadu Agricultural Income-tax Act. Thus there is an escapement of 46.64 standard acres. In order to bring the escaped extent of assessment and to levy additional tax, a notice under section 65A(3) of the Act was issued to the assessee. The total standard acres for the three years of 1987-88, 1988-89 and 1989-90 was worked out to 126.57. The total standard acres for 1990-91 was worked out to 114.17. The total tax on the above standard acres were worked out and levied and the difference payable was demanded, by issue of show-cause notice to the assessee on August 21, 1991. No objection was received from the assessee, and in the circumstances the assessment was confirmed. According to the respondents, it is very clear that the petitioner's lands can be called tope containing valuable timber trees. The casuarina tope could be considered to be timber trees and it is used as fire wood. In the circumstances, the Casuarina tope would fairly fall under section 2(y) of the meaning of the Act and the assessment as 1 : 1 standard acres under the Act is justified. According to them, the assessment order dated November 11, 1991, clearly mentions about that from the first 20 standard acres of land, no assessment is made and assessed as nil tax, and next standard acres are only sub-jected to assessment. The show-cause notice proposing to the assessment years 1987-88 to 1990-91 was issued to the petitioner on August 2, 1991. According to them, the assessment order dated November 11, 1991, clearly mentions about that from the first 20 standard acres of land, no assessment is made and assessed as nil tax, and next standard acres are only sub-jected to assessment. The show-cause notice proposing to the assessment years 1987-88 to 1990-91 was issued to the petitioner on August 2, 1991. Since the petitioner did not file any objection to the pre-assessment notice, final orders have been passed by order dated November 11, 1991. According to them, the orders have been passed after taking into consideration the factual circumstances of the issue. Hence, the order passed is valid. According to them, the revision petitions which were filed by the petitioner before the first respondent were taken up for hearing on January 31, 1992, and the contentions of the petitioner were examined in detail and the revision petition was dismissed and the petitioner's land is sub-jected to assessment under 1 : 1 ratio of the standard acres. Further, according to them, in a taxing statute, words which are not technical expressions or words of art, but are words of every day use, must be understood and given a meaning not in their technical or scientific sense, but in a sense as understood in common parlance. They contended that the expression "timber" has an accepted and well recognised legal connotation and it has also a popular meaning as a word of every day use. It has been mainly used as timber for fuelwood, building material and used for the purposes of pandals and in these circumstances, the casuarina trees could be considered to be a timber and if it is grown in groups would be called tope within the meaning of section 2(y) of the Act and has been rightly brought under the purview of section 2(vv) of the ActHaving seen the entire material available on record and from the facts and circumstances of the case and also from the claims and counter claims made by the rival parties, the following are the admitted facts, The petitioner herein and three others are owners of 126.57 ordinary acres of land in the Anoor Village, Chennai, MGR District. They were assessed for the assessment years 1987-88, 1988-89 and 1990-91 on extent of 126.57 ordinary acres equivalent to 79.93 standard acres. They were assessed for the assessment years 1987-88, 1988-89 and 1990-91 on extent of 126.57 ordinary acres equivalent to 79.93 standard acres. During the verification of the assessment year records it was noticed that the casuarina cultivated in an extent of 69.96 acres has been categorised under the ratio 3 : 1 as against 1 : 1 as per the provision of section 2(vv)(xii) of the Act. Thus there is an escapement of 46.64 standard acres. In order to bring the escaped extent of assessment and to levy additional tax, a notice under section 65A(3) of the Act was issued to the assessee. The total tax on the standard acres were worked out and levied and the difference payable was demanded by issue of show-cause notices to the assessee on August 21, 1991. No objection was received from the assessee and in the circumstances the assessment was confirmed. Aggrieved against the order dated November 11, 1991, the petitioner preferred revisions to the first respondent. The first respondent took up the revision petition filed by the petitioner for hearing and considered the issue factually and final orders were passed in his R.P. Nos. 6 to 9/92, dated February 21, 1992, confirming the orders of the second respondent. The main grievance of the petitioner is that the lands in question are used for growing Casuarina should be computed into standard acres on the basis of 3 : 1 and not as computed by the assessing authority as 1 : 1 standard acres. As rightly contended by the respondents, the contention of the petitioner that the ratio of 1 : 1 is applicable only to other than coconut trees and hence the adoption of the ratio 1 : 1 is not justified. But the definition of the concerned clause goes to show that the petitioner's lands can be called tope containing valuable timber trees. It is significant to note that the casuarina tope could be considered to be timber trees and it is used as fire wood and as rightly contended by the respondents in the circumstances the casuarina tope would fairly fall under section 2(y) of the meaning of the Act and the assessment as 1 : 1 standard acres under the Act is justified. That apart the assessment order dated November 11, 1991, clearly mentions that the first 20 standard acres of land, no assessment is made and assessed as nil tax, and next standard acres are only subjected to assessment. Further show-cause notice proposing to the assessment years 1987-88 to 1990-91 was issued to the petitioner on August 21, 1991. Therefore, it is rightly contended by the respondents that since the petitioner did not file any objection to the pre-assessment notice, final orders have been passed by order dated November 11, 1991. A perusal of the impugned orders goes to show that the orders have been passed after taking into consideration the factual circumstances of the issue and they cannot contend that the impugned orders have been passed mechanically. Thus it is the categoric contention of the respondents that as per the definition clause the petitioner's land is correctly subjected to assessment as 1 : 1 ratio standard acres. In the above facts and circumstances, I see every force in the said contentions of the respondentsTherefore, for all the aforesaid reasons and in the facts and circumstances of these cases and also in view of my above discussions with regard to the various aspects of these cases, I am of the clear view that the petitioner herein has failed to make out any case in his favour and that, therefore, there is no need for any interference with the orders impugned in these writ petitions. Thus, the writ petitions fail and are liable to be dismissed for want of merit. In the result, the writ petitions are dismissed. No costs. Consequently, all the connected WMPs are also dismissed.