Judgment

D.P. Wadhwa, J.-A common question of law in both these appeals is : If the Board, i.e., Board of Trustees of Visakhapatnam Port Trust is exempt from taxation under Article 285 of the Constitution from levy of property tax by the Visakhapatnam Municipal Corporation, constituted under Visakhapatnam Municipal Corporation Act, 1979 (Civil Appeal No. 1810 of 1988) and also from levy of non agricultural land tax by the Visak­hapatnam Mandai under the Non-Agricultural Lands Assessment Act, 1968. Contention of Mr. Kailash Vasudev, learned counsel appearing for the Board is that the properties are not owned by the Board and the vest­ing of the properties in the Port Trust is only for the purpose of administering them and they in fact demained the properties owned by the Union of India and thus exempt from taxataion under Article 285 of the Constitution. Under this Article property of the Union of lndia is exempt from all taxes imposed by the State or by any authority within a State.

2. The Board of Visakhapatnam Port Trust is constituted under the Major Port Trust Act, 1963. Constitution of the Board is described in Section 3 of the Act. Under Section 5 Board shall be a body corporat