Judgment

D.P. Wadhwa, J.-Food Corporation of India (‘Corporation’ for short) is aggrieved by judgment dated October 31, 1989 of the Andhra Pradesh High Court holding that Corporation is liable to non-agricultural land tax amounting to Rs. 20,994.80 for the fasli years 1384 to 1397. The tax is revied under the Andhra Pradesh, Non-Agricultural Lands Assessment Act, 1963 (for short the ‘Act’). Before the High Court Corporation had challenged the order of the appellate authority under the Act confirm­ing the demand issued for collection of non-agricultural land tax for 14 years. The demand was raised by Palakole Mandal, West Godavari District, Andhra Pradesh.

2. Two contentions have been raised before us : (1) Corporation is exempt from taxation under Article 285 of the Constitution and (2) assessment has to be made for each year and respondent No. 2 Palakole Mandal could not make assessment for 14 years on one go.

3. Corporation is constituted by the Food Corporation Acr, 1964. In our Judgment in Civil Appeal No. 7054 of 1995 Food Corporation of India v. Municipal Committee, Jalabad & Anr.1 , 1999(6) Supreme we have held that Corporation cannot claim exemption from taxation under Article