S. RAVINDRA BHAT, J.

1. The petitioner school is aggrieved by a Show Cause Notice dated 24.01.2013 and consequential Assessment Order dated 19.06.2015, both issued by the North Delhi Municipal Corporation (hereafter called “the Corporation”).

2. The admitted facts are that the petitioner has and continues to file returns as required by the provisions of the Delhi Municipal Corporation Act, 1957 [hereafter “the Act”] in respect of the premises under its control. It also deposits the municipal taxes and property taxes in terms of its returns from time to time. With the amendment to the Act in 2003 and the introduction of the “Unit Area Method” of valuation and consequential assessment, it consistently reported and paid taxes on a self-assessment basis. While doing so, on 24.01.2013, it received a notice in the following terms :

“M/s. Patel Education Society

Springdales School,

Pusa Road, New Delhi-05

Subject: Assessment of Property no.Springdales School, Pusa Road Under Section 123D of DMC (Amendment) Act, 2003.

Whereas, as per available record, Self-assessment Property Tax Re