( 1 ) WHETHER properties lying on the border line of the Union Territory of Delhi and the adjoining State are liable to municipal property tax of Delhi is an important question of law arising in this petition. To put it in a different form, the question is which municipal authority is entitled to collect property tax (general tax) Delhi Municipal Corporation or the municipal authorities in the adjoining States ? The difficulty has arisen in the present case because two municipal authorities have levied and collected property tax from the petitioner in regard to same property for the same year. Property bearing Municipal No. 483/49-B at G. T. Road Shahdara-Delhi-cum-U. P. border touches Union Territory of Delhi from north and east while from South and West side the property touches Uttar Pradesh (particularly territory comprising of Nagar Palika, Ghaziabad ). The property in question is used as a godown. It has no access from Delhi side. Admittedly, the access is only from U. P. side. Admittedly, because although it was asserted in the affidavit in reply by the Delhi Municipal Corporation that there is an access from the eastern side opening in Union Territory of Delhi, on