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Assessment of annual value of row of quarters as a 'building' for house tax under the Punjab Municipal Act, 1911. Analysis: The Supreme Court considered the interpretation of the term 'building' under the Punjab Municipal Act, 1911. The case involved the Notified Area Committee assessing the annual value of a row of quarters in one block as a single 'building' for levying house tax. The Respondent Board had constructed residential houses at Nangal township for its officers, staff, and workers. Each bungalow and quarter had separate boundary walls, distinct house numbers, and were allotted to individual officers and employees. The Committee raised the annual value for house tax by treating the entire block as one building, contrary to assessing each quarter individually as done previously. The issue revolved around whether each separate residential unit should be considered a building for house tax purposes. The Board objected to the Committee's assessment, arguing that individual quarters should be treated separately, especially those with annual rental values not exceeding a certain threshold exempt from house tax. The Board's objections were initially rejected, leading to an appeal before the Deputy Commissioner, which was dismissed. Subsequently, a writ petition was filed in the Punjab & Haryana High Court, where a single Judge ruled in favor of treating each unit as a separate building for house tax assessment. The Committee contended that all quarters in one block should be considered one building to increase the annual value and subsequently the house tax revenue. However, the Supreme Court disagreed with the Committee's approach. It emphasized that each quarter or bungalow, being a place of dwelling for individual employees, falls within the definition of 'building.' The Court rejected the Committee's argument that common walls between quarters in a row should consolidate them into one building for tax assessment purposes. The Court found the Committee's stance aimed at maximizing revenue unjustified and dismissed the appeals, affirming the High Court's judgment. In conclusion, the Supreme Court upheld the High Court's decision, dismissing the appeals and ordering the Committee to refund any excess tax paid by the Board within two months. The judgment clarified that each residential unit should be treated as a separate building for house tax assessment, based on the definition and purpose of 'building' under the Punjab Municipal Act, 1911.
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