Query under MAharashtra Land Revenue Code

At the time of granting the order of non-agricultural residential plots, the District collector of Sangli (Maharashtra) has charged conversion tax on the entire agricultural land. In fact, it should be charged on the area under non-agricultural plots. In other words, it should not be charged on the roads and open spaces which are handed over to the local authorities and no construction is allowed on it. Whether my view is correct? I need supporting decision. (Ref. Rule 22(2) of the MLRC)