1. The petitioner is the Mother Superior of Santhi Bhavan, Thrikkakara. She challenges Ext. P3 order of the Government rejecting her application under S.144 (3) of the Kerala Panchayats Act, 1969, by which she questioned the correctness of the appellate order passed by the Deputy Director of Panchayats confirming an assessment made by the 2nd respondent-Panchayat in respect of the petitioner's building. The building was assessed under the Kerala Panchayats Act, 1960 ('the Act'). The petitioner claimed exemption from tax as per the provisions of S.72. She contended that the building was used as a place of worship and as a place for educational purposes. She stated that education was imparted to the students who lived in the building. The building was thus used as a place of residence exclusively for students undergoing religious and college studies. These facts have not been denied. On the other hand these facts have been accepted. In the impugned order this is what is stated by the 1st respondent:

"It is only a lodging place for students who undergo religious and college studies."

The building is thus accepted as a place of residence for students who undergo religious and