JUDGMENT - KHANDEPARKAR R.M.S., J.:---Heard the learned Advocates for the parties. Perused the records.

2. The petitioners are challenging the orders and the notices issued by the respondents in relation to demand of tax as well as the warrant of attachment pertaining to the property of the petitioners as well as the order of cancellation of exemption from payment of property tax on two grounds, namely, that the rateable value has been assessed in contravention of the order of the Apex Court in the matter of (The Municipal Corporation of Greater Bombay v. M/s. Polychem Ltd.)1, reported in A.I.R. 1974 S.C. 1779, in as much as the same is on the basis that the land is under construction and not a vacant land, and secondly, that the exemption from payment of tax has been revoked, firstly, in contravention of the basic principles of natural justice, and secondly, that the same is contrary to the provisions of law as well as the ruling of the Apex Court in the matters of (Christian Children Fund Inc. v. Municipal Corporation of Delhi and others)2, reported in 1994(4) S.C.C. 337, and (Christ The King Cathedral v. John Ancheril and another)3, reported in 2001(6) S.C.C. 170, and it is also

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