{"id":107814,"date":"1982-07-13T00:00:00","date_gmt":"1982-07-12T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/electronics-corporation-of-india-vs-the-secretary-revenue-on-13-july-1982"},"modified":"2016-07-12T07:47:08","modified_gmt":"2016-07-12T02:17:08","slug":"electronics-corporation-of-india-vs-the-secretary-revenue-on-13-july-1982","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/electronics-corporation-of-india-vs-the-secretary-revenue-on-13-july-1982","title":{"rendered":"Electronics Corporation Of India … vs The Secretary, Revenue … on 13 July, 1982"},"content":{"rendered":"
Andhra High Court<\/div>\n
Electronics Corporation Of India … vs The Secretary, Revenue … on 13 July, 1982<\/div>\n
Equivalent citations: AIR 1983 AP 239<\/div>\n
Author: J Reddy<\/div>\n
Bench: M Rao, J Reddy<\/div>\n<\/p>\n
<\/pre>\n
JUDGMENT<\/p>\n
 Jeevan Reddy, J. <\/p>\n
 1. Andhra pradesh Non-agricultural  Lands  assessment Act.  1963  was enacted  by the  state of Andhra pradesh to provide for the levy of assessment  on lands used  for  non-agricultural  purposes.  It has been amended by the  andhra  pradesh Act (No. XXVIII)   to  1974, which  amendment  Act came into force on 1-7-1974  the Amendment Act amended the  definition of owner” in cl. (J)  of sec. 2 along  with certain other provisions of the Act.  The definition of  “owner” reads as follows:-\n<\/p>\n
 “Owner’ includes any person for the  time being receiving  or entitled to receive whether on his own  account or as agent trustee guardian Manager, or receiver for  another person or for any religious educational or charitable  purpose rent or profits for the  nonagricultural  land or for the structure constructed on such  land in respect of which the  word is   used  and also includes in respect of the  land  owned  by the  state  Government  or the   central Government.\n<\/p>\n
(i)  a lessee. If  the land has  been leased out by the Government for any  commercial  industrial  or other non-agricultural   purpose; and<\/p>\n
(ii)   a local authority, if the  land  is vested  in the local  authority and used  for  any commercial  industrial or other non-agricultural  purpose deriving  income  therefrom”.\n<\/p>\n
We may also notice the definition of  ‘occupier and non-agricultural  land continued in cls.  (I)  and (g)   respectively   of sec. 2:-\n<\/p>\n
“Occupier’ includes-\n<\/p>\n
(1)   any   person  for the time  being  paying or liable to pay to the owner  rent  or any portion of the rent  for the non-agricultural  land or for the  structure  constructed  on such land or part of such lnad or structure. In  respect of which the  word is used or damages on account of the  occupation of  such land   structure or part : and <\/p>\n
(ii)  a rent-free occupant”.\n<\/p>\n
“Non-agricultural land”  menas land  othere  than the   land  used exclusively for the purpose of agriculture   but does not include the land was exclusively for include the land   used  exclusively for-\n<\/p>\n
(i)  cattle  sheads;\n<\/p>\n
(ii)   hay-ricks”.\n<\/p>\n
Section 3 if  the charging  section  It reads to the following  effect:-\n<\/p>\n
 “3.  Levy  of  assessment of non-agricultural  lands.\n<\/p>\n
 (i)  in the  case of  of non-agricultural  land in the local  area with the population  specified in col.  (1)  of  the schedule there shall be levied and collected  by the Government for each  Fasli year commencing  on hte first day of July,  from the owner  of such  land  an assessment at the rate   specified  in col (2)   where the land is used  for any  industrial  purpose.  At the  rate specified against  it in col.  (3)  where  the land is  used  for  any commercial  purpose and at the  rate specified against it in col.  (4)  Where the  land is  used  for  any  other  non-agricultural  purpose including residential purpose;\n<\/p>\n
Provided that where  assessment is levied and collected in  respect of such  land under this Act no land  revenue shall be payable   in respect  of that  land and  nothing  contained  in any  enactment,  regulation,   order   bye-law. Rule, Scheme  notification. Or  other instrument  having  the force of law, in  operation immediately   before  the   commencement  of this Act relating   to the assessment  levy and collection  of land revenue  on  non-agricultural   land  shall  apply in respect of  that  land.  Except  as respect things  doen or omitted to be done  before  the commencement   of the  aact.\n<\/p>\n
Provided further  that any amount  payable   on such land at the commencement of this   Act   towards the arrears  of  land revenue    may be recovered  under  the provision of the  andhra  pradesh    Revenue  Recovery  Act 1864.\n \n\nEXPLANATION:- Where  the land  is used for any industrial  of commercial purpose and also for  any other  nonagricultural  pupose  such  land  shall be assessed at the  rates specified  in  col.   (2)  or col  (3)   of the  schedule  as if it  were used   solely for   any  industrial or commercial  purpose as the case  may be.\n \n\n(2)  Notwithstanding  anything contained in sub-sec. (1)   where  the  assessment leviable  on any non-agricultural  land under this Act is less than the  land  revenue   alone shall be payable   on   that  land\". \n \n\n2.  The land  of levy is provided in  the  schedule to  the Act and sec. 6 8 empowers the stat Government  to  amend  the same  from time to time.  Indeed the schedule was  also  amended by the  aforesaid  Amendment  Act.\n \n\n<\/pre>\n
3.  The writ petitioner herein  is the electronics corporation of iNdia  ltd., MOulali,  Hyderabad.  A  notice of demand  was served  upon   by the  petitioner calling upon  it to pay  a sum of Rupees  11,98,826-32  Ps.  Towards  the years 1974-75  to 1978-79, and  a  further   sum of Rupees 1, 91.189-68 Ps.  For the  years 1970- 71  to 1973-74,  on account   of the nonagricultural  tax due  under the  Act.  The   present  writ  petition is filed  questioning the said demand.\n<\/p>\n
4.  The contention of hte writ  petitioner is that it is a  lessee of the land  which belongs to the Union of India and since the property of the Union of India  cannot be taxed  by a state legislature the  andhra  pradesh  Non-agricultural  Lands  assessment  Act.  1963  cannot apply  to the  property owned by  the  Union  of India  and  accordingly  no  demand  can be  made upon  the petitioner,  which is  a lessee of the Union of India.  It is stated  that an area  of aproximately  1000  Acres  was granted  by the   state Government to the department  of Atomic Energy  Government of India and the  Department of Atomic Energy  in turn  leased out an  extent of 280-25  acres to the petitioner-corporation for  establishing its plant and machinery.  It is further contended, that  out of the extent  granted  to the petitioner an extent of 29 acres  is covered by buildings;  an extent  of 12 acres   is  covered  bu buildings;  an extent of  12 acres  by roads and the rest of the  area  is meant  for  future expansion It is  also submitted that an extent of 14.25 acres is being  used for  agricultural  purposes.\n<\/p>\n
5.  In the  counter-affidavit  filed by the respondents the  fact of grant  to the  Union of India, Atomic  energy department   and the  lease  by the  atmoic  energy  Department to the writ petitioner, have not  been denied.  We shall  therefore have to take the  said  facts  as true and proceed on that basis.\n<\/p>\n
6.  Article  285  of  the  Constitution  reads as follows:-\n<\/p>\n
“285.  (1)  The property  of the Union shall, save in so far as parliament  may by law  otherwise  provide be exempt  from all taxes  imposed by a  state or   by any aauthority within a state.\n<\/p>\n
(2)   Nothing  in cl.  (1)  shall until  parliament  by law  otherwise   provides  prevent  any authority within a state from levying  any tax on any  property  of the union  to which  such property  was immediately   before the commencement of this Constitution  liable  or  treated as liable  so long as that  tax continues to  be levied  in that  state”.\n<\/p>\n
This  Article   corresponds  to sec. 154  of the Government  of India    Act,  1935.  Cl. (1)  of art.  285  declares  that the property of the Union shall be  exempt  from all taxes  imposed  by a state except   in so far as the parliament  may be law provide otherwise  the  contention of Sr. P. R.  Ramachandra  Rao,  the learned  counsel for the  writ  petitioner,  is that inasmuch  as the property  upon  which the  non-agricultural   tax is  being  levied  is the property of the Union the  State  Legislature   is not competent   to    levy and tax   thereon.  The   is disputed  by sri  N. Subba Reddy, the learned Government <\/p>\n
Pleader  with   reference to the language  of sec. 3 read with the definition of owner in the Act His contention is that  the levy is not  upon  the property of the Union, but is upon the  interest of the lessee\/occupier  and that  therefore the bar in Art. 285  has no application.  We  are inclined to agree with Mr. Subba Reddy.\n<\/p>\n
7.  The definition  of the  expression  “owner”  in cl. (J)  of sec. 2 is an  inclusive definition.  It includes (j)   any  person for hte time  being receiving  or entitled to receive whether on his own account  or  as agent.  Trustee  guardian  manager or receiver.  For another person or  for  any religious  educational.  Or  charitable   purpose rent or  profits for the  non-agricultural  land or for  the  structure constructed on such land in  respect of which the   word is used:\n<\/p>\n
  (ii)  a lessee of the  land  owned  by hte   state Government or the  central Government.  Provided the lease has been granted  for  any  commercial, industrial  or other non-agricultural  purpose; and  (iii)   a local  authority. If the land is vested in the local  authority and is used for  any commercial   industrial or other  nonagricultural  purpose deriving  income  therefrom.\n<\/p>\n
8.  Now coming to the charging  section sec. 3 91)  levies the  assessment on the land used for  industrial commercial or other  non-agricultural  purpose, including  residential  purpose, and  declares  that it shll be collected  from the owner of such land.  It is  significant to notice that the assessment is not levied on  the  non-agricultural  land as such but only on such non-agricultural  land  as is  used for industrial   commercial or other  non-agricultural   purpose, including   residential purpose.  What attracts  the assessment  is the user for  specified purposes.  The  expression  Owner’  occurring  in section 3  (1)  must be  understood it would  follow  that in clause of lands  owned  by the  central  Government the  levy is upon  the lessees’   interest, provided  the land has been leased out by the   central  Government for any commercial, industrial  or other non-agricultural  purpose and  to the extent it is used for any of those purposes.  Looked at from this angle  the tax or assessment as the case may be, is not levied  upon the property  owned  by the  central  Government but upon the interest of the  lessee in  such  land.  The two  privy council  decisions which we shall presently  refer to deal  with  almost a similar  situation  and as we shall point  out presently, the principle of those  decisions clearly  governs the  present  case.\n<\/p>\n
9.  The  first decision is in smith v. Vermillion Hills Rural  council  (1916)  2 AC 569. Sec. 125 of the British North  American  Act, 1867  provided that “no lands or property belonging to canada or any province shall be liable  to taxation”.  The appellant was granted a lease  by the  crown in respect of certain lands for grazing purposes.  The  lands leased were  situated within a  local  improvement   District, which  was subsequently organized  as a Municipality.  Under a statute of the province the Municipality levied  a tax upon  “every  owner  or occupant in the district for land  owned  or occupied by him”  ‘Owner  was defined to include any person who has  any right title or estate whatsoever or any interest other than that of a mere occupant in any land “occupant” was  defined to include the inhabitant occupier of any land or, if there be no inhabitant  occupier, the  person  entitled to the possession thereof,  and the lease holder or holder under agreement for sale.  And any person having or enjoying in any way or for any purpose whatsoever, the  use of the  land  “Land” was defined to include, inter alia any estate or interest therein.  The appellant questioned the levy on hte ground  that if amounts to a levy on the ground  that if amounts to a levy upon the land owned by the  dominion of canada and was therefore violative  of S. 125 of the British  North-America Act, 1867  (Constitution of canada).  The specific contention of the appellant was that the tax  was levied upon the land itself which belongs to the crown and not on any  individual  who has interest in it while the contention  of  the Municipality was  that the tax  was levied  upon  the interest of the appellant as  a lessee of the land, and  not on  the land itself a sowned by the  crown.  The principle   of the decision of the privy council is to be  found in the following  observations:\n<\/p>\n
  “Following their decision in the analogous case from Alberta of calgry and Edmonton Land co. V,  Attorney General of Alberta (45 can SCR  170), Where  the scheme and definitions in the local improvement  Act of that province were substantially the  same as  those in the  present case, the  Supreme Court  of canada held that  the  taxing  statute of Baskatchawan must be read in accordance with a well  known principle as not applying to the crown or its lands.  But they thought that there was no reason why it  should not be treated  as applying to an interest acquired by a  private person under a lease from the  crown.  The definitions of land Owner and occupant’ make  it easy  to interpret the expression land as excluding any interest which still remains in the crown.  Their  Lordships agree with this reasoning.  They  are of opinion that alothough the appellant is sought to be taxed  in respect of his occupation of land the fee of which is in the crown.  The operation of the statute imposing  the tax  is   limited to the appellant’s  own interest.  It  appears to  them that  not only can the statutes be read as meaning this and no more than this when they use  the  word “land” but  that  they ought to be so read in  order to make them consistent with S. 125 of the British North America Act 1867 and not a nullity………………”\n<\/p>\n
10.  A similar  case again arose in city of Montreal v. Attorney  General  for  canada (1923) AC 136 again from canada the facts of which case are very much similar  to the case before  us.  Art.  362-A of the city of  Montreal charter.  Provided that persons occupying for  commercial  or industrial purposes buildings or lands belonging to His  Majestry or to the Federal  and  provincial Government or to the Board  of Harbour commissioner……shall be taxed  as if they  were the actual  owners of such immovables and shall be held to pay the annual  and special   assessments.  Taxes  and other municipal dues”.  In that case the  Minister of Railways and canals for canada representing  the crow granted a lease in respect of certain  crown lands  in the city of Montreal to one Andhrew Baile, for a  period  of five years.  This  property was subjected to the tax   aforesaid  and the same was demanded.  When  the  taxes demanded were  not paid  an action was laid which though  not defended by the lessee, was contested by the  attorneyGeneral for canada who  contended  that  art 362-a was Ultra vires the Quebec legislature and is   unconstitutional in so far as it applied to hte occupants of lands belonging to the crown which are exempt by virtue of S. 125 of the British North America Act.  When the matter ultimately came up before the  privy council.  It referred in the first instance to hte relevant  provisions of the charter of the city of montreal and then noted that Art. 361  enacts that all immovable  property situated  within the limits of hte city shall be liable to taxation and assessment, exempt therefrom.  Admittedly  there was no exemption in the Act in favour of  the Crown lands  leased out to the subjects.  The contention  of the  Attorney  General  for canada  however was that the Municipality is in effect seeking to tax the property of the crown indirectly  by levying a tax  upon the occupants\/Lessees and that such taxation is ultra vires its  power the attorney general  however agreed that if the tax is  imposed  in such a  form that it is in reality a taxation on the interest  of the  tenant or occupant and not on  the property of the  crown such a law would not be ultra vires the provincial Legislature; in view of the earlier  decision of hte privy council  in smith’s  case (1916-2  Ac 569)  (supra)  the following  passage  in the Judgment  brings out the  essence of the decision:  The question raised in   this appeal, is, however, in  the main dependent  on the further  enactment  that the occupants shall be taxed  as if they were the actual  owners  of immovables and shall be held to pay the annual   and special  assessments the taxes  and other municipal  dues.  The effect of this is  that the occupants are made liable to pay on an annual  assessment,  not to exceed 1 per cent of  the capitalized value of the occupied  property.  The  method of assessment determines  the amount for which an occupier  is liable during his  occupancy, but does not alter  the incidence  of the taxation  or transfer the incidence  from the  occupant to the owner.  The  ultimate incidence of taxation imposed on  tenants, as  the  occupants of lands is a matter on which economic  experts have expressed different opinions.  If however municipal  taxation is to be regarded as ultra  vires on hte ground that the ultimate incidence of taxation or some portion of it, may or will  fall on the owner it is  difficult  to see in  what  from such taxation could  be validly imposed.  The question to be determined is simpler one whether  the taxation which is  impeached,  is  assessed on the interest of the occupant and imposed on that  interest.  In the opinion  of their  Lordships  the interest of an occupants consists in the benefit of the occupation to him   during the period  of  his  occupancy and does not depend  on the length  of his yenure.  The  annual  assessment  to which  objection is taken  is an assessment for which the tenant  is only liable  so long as  his occupancy continues  and which  ceases so soon as his occupancy is determined if on the cessation of his tenancy the crown chooses to leave the land unoccupied or to occupy  the land by an official acting  in his official capacity, there would be no further liability to taxation  under  art. 362-A of the charter affecting either the land  or the crow……….”\n<\/p>\n
We respectfully agree with the  above  reasoning.  The assessment of nonagricultural land tax under S. 3 (1)  is  made in this case not upon the propoety of union  of India.  (Central Government being the  owner  of the property)  but upon the  interest of the     lessee under the central  Government as per the definition of the word owner  under S. 2 (j)  of the a.P. Non-Agricultural land Assessment Act 1963   lessee under the central  Government is deemed to be the  owner  for the  purpose  of assessment of tax.  Art.  285  is therefore not attracted in such a case.  The  state Government   can   levy  and collect  the tax   from  the petitioner under S. 3 (1) of the said  Act  only so long as he continues as lessee of the  central Government  property.  We make  it clear that the  tax  can be levied only if the lease for any  commercial  industrial  or other  non-agricultural purpose.  Of course in this  case, there  is no dispute that the lease is for an  industrial purpose.\n<\/p>\n
11.  We must further make it clear, following our  decision in W.P. 3494  of 1978  and batch  disposed of on 10-6-1982: ()  that the non-agricultural  tax  can be levied only upon that land  which is,  actually used for any of the specified  purposes. Viz  commercial  industrial or any other non-agricultural  purpose including residential purpose.   What extent of land  is so used, and which is  the  appropriate  rate applicable to the petitioner, is a matter for the  assessing  authorities to decide.  Having  regard to the facts of this case,  and following  the similar directions given by us in the aforesaid batch  of writ petitions, we  direct that if the petitioner herein files  an appeal  within a period  of one month from today before the appellate authoirty against the demand impugned   herein the appellate authority shall entertain the same and  shall dispose of the same   on merits In such an appeal  it shall be open to the appellants to establish the  actual extent of the land used for the  aforesaid purposes.  Which rate or  rates mentioned  in the schedule to the Act are applicable  can  also be gone into and decided in such an appeal pending  disposal of the appeal, we direct that  the  demand  impugned herein shall  remain stayed.\n<\/p>\n
12.  Subject to the  above directions,  the writ  petition is dismissed; but, in the circumstances, we make no order  as to costs.  Government pleader’s  fee Rs. 500\/-  only.\n<\/p>\n
13. Order accordingly.<\/p>\n","protected":false},"excerpt":{"rendered":"
Andhra High Court Electronics Corporation Of India … vs The Secretary, Revenue … on 13 July, 1982 Equivalent citations: AIR 1983 AP 239 Author: J Reddy Bench: M Rao, J Reddy JUDGMENT Jeevan Reddy, J. 1. Andhra pradesh Non-agricultural Lands assessment Act. 1963 was enacted by the state of Andhra pradesh to provide for the […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[10,8],"tags":[],"class_list":["post-107814","post","type-post","status-publish","format-standard","hentry","category-andhra-high-court","category-high-court"],"yoast_head":"\nElectronics Corporation Of India ... vs The Secretary, Revenue ... on 13 July, 1982 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/electronics-corporation-of-india-vs-the-secretary-revenue-on-13-july-1982\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Electronics Corporation Of India ... vs The Secretary, Revenue ... on 13 July, 1982 - 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