K. Balakrishnan Nair, J.

1. The point that arises for decision in this Writ Petition is whether the building used for the residence of nuns in a convent is eligible for exemption from Building Tax in terms of Section 3 (1) (b) of the Kerala Building Tax Act. The brief facts of the case are the following:

2. Adoration convent is a convent established by a religious congregation known as "The Sisters of Adoration of the Blessed Sacrament". The main purpose of the establishment of a convent is to provide residential accommodation to the nuns who may be undergoing eight years' religious training to become a nun and for living thereafter while undertaking religious, charitable or educational activities. The above said congregation constructed a convent building at Thodupuzha. When the Tahsildar, the assessing authority, under the Kerala Building Tax Act, 1975 directed the convent to file the statutory return, it filed a return claiming exemption from the provisions of the Act under Section 3 (1) (b) on the ground that the building was one principally used for religious purposes. The said provision reads as follows:

"3. Exemptions.-- (1) Nothing in this Act shall apply to-

(a) xxx