Judgment :- Challenge in this Writ Petition is the assessment of Urban Land Tax for the lands in the name of Petitioners husband – Late Nambi Srinivasan. 2. Facts in a nutshell are as follows:- A notice in Form – 4B dated 28.02.1991 was issued to the land owner, inviting objection for the proposed assessment of the land in S.No.693 pt, 696 pt, 703/1A, 1099/2, Kulavanigarpuram Village, Palayamkottai. Neither the land owner nor the Writ Petitioner attended the enquiry on the hearing dates fixed. Construing that land owner or the Petitioner had no objection for the proposed amendment, assessment was made from Fasli 1391 to 1403. 3. Aggrieved by the said assessment, the Writ Petitioner preferred revision before the Special Commissioner – first Respondent under Section 30 of Urban Land Tax Act, 1966 (for short, the Act). 4. Before the Commissioner, the main contention raised by the Petitioner is that assessment orders are passed in the name of her husband and on that date, he was not alive and that the lands are agricultural lands and cannot be fixed under Tamil Nadu Urban Land Tax. The first Respondent rejected the Revision Petition on the following grounds: - .(i) major portion of the lands were acquired and vested with the Government and entire liability of tax has not come to the Petitioner; .(ii) though the assessment orders were duly served, Revision Petition was filed only in November 1999, which is barred by limitation. 5. On behalf of the Petitioner, the learned Senior Counsel Mr.N.R.Chandran has mainly raised contention that the impugned assessment has been made in the Petitioners husbands name – Nambi Srinivasan and the assessment made in the name of a dead person is flawed. Among various grounds, one of the grounds urged is that provisions of Tamil Nadu Urban Land [Ceiling and Regulation] Repeal Act, 1999, Act 20/99, was not kept in view by the authorities. 6. During the course of arguments, the learned Senior Counsel Mr.N.R.Chandran, has submitted that though the Petitioner had raised the contention before the authorities that case lands are agricultural lands, the Petitioner is giving up that plea. 7. 6. During the course of arguments, the learned Senior Counsel Mr.N.R.Chandran, has submitted that though the Petitioner had raised the contention before the authorities that case lands are agricultural lands, the Petitioner is giving up that plea. 7. On revision filed before the Special Commissioner, the second Respondent appears to have reported to the Special Commissioner "that assessed lands in S.No.693 pt, 696 pt and 703/1A were acquired by Government on 29.07.1988 by treating the lands as Urban Vacant Land, in excess of ceiling limitation under the provisions of Tamil Nadu Urban Land (Ceiling and Regulation Act), 1978", which was then in force. The Special Commissioner appears to have recorded the same stating that major portion of the lands assessed have been taken over. At the time when the impugned Order was passed by the Special Commissioner on 14.09.2000, Tamil Nadu Urban Land [Ceiling and Regulation] Repeal Act, 1999, Act 20/99 was in force. 8. Placing reliance upon 2002 (2) LW 764 [C.V.Narasimhan Vs. The Government of Tamil Nadu and 2 others], and W.P.No.35490/2004, decided on 27.09.2005, the learned Senior Counsel has submitted that while considering the impact of the Repealing Act, the Courts have held that where physical possession of such land continues to be with the owner, statutory vesting under Section 11(3) of the Act is of no relevance. It was further submitted that without keeping in view the Repealing Act 20/99, the Special Commissioner has erroneously recorded that major portion of the lands were acquired and vested with the Government. On this contention, this Court does not propose to express its views, in view of the limited scope in this Writ Petition. 9. Assessment Order was made in 1994. Admittedly, Petitioners husband died on 19.06.1989. Notices were sent in the name of Petitioners husband – Nambi Srinivasan [dead person]. The impugned assessment was also made in the name of the dead person and the same cannot be sustained. 10. According to the Petitioner, she came to know about the assessment only when Notice of Demand was served upon her on 06.08.1999. It is relevant to note that after serving of demand notice on 011. 1999, the Petitioner has paid Rs.14,055/- and Rs.31,431 on 111. 1999 towards Urban Land Tax. 10. According to the Petitioner, she came to know about the assessment only when Notice of Demand was served upon her on 06.08.1999. It is relevant to note that after serving of demand notice on 011. 1999, the Petitioner has paid Rs.14,055/- and Rs.31,431 on 111. 1999 towards Urban Land Tax. As regards S.No.1099/2, according to the Petitioner, she does not own any land in S.No.1099/2 – 16.00, which have been taxed under Urban Land Tax Act for Fasli from 1391 to 1403. Since substantial points have been raised and the impugned assessment were made in the name of dead person, the Special Commissioner ought to have condoned the delay in filing the Revision Petition and ought to have remanded the matter to the second Respondent – Assistant Commissioner, for fresh consideration. Immediately after serving of Demand Notice, the Petitioner has also shown her bonafide by paying Urban Land Tax demanded from her. In view of the substantial contentions raised by the Petitioner, the Petitioner ought to be given an opportunity and the matter is to be remanded to the second Respondent for considering the matter afresh. 11. This Revision Petition is allowed and the impugned Order of the first Respondent is quashed. The matter is remanded to the second Respondent – Assistant Commissioner to reconsider the entire matter, keeping in view the Tamil Nadu Urban Land [Ceiling and Regulation] Repeal Act, 1999, Act 20/99, and consider the matter afresh after affording sufficient opportunity to the Petitioner.