Heard both sides.

2. The petitioner in both the Writ Petitions is the Principal Accountant General (Civil Audit), Tamil Nadu and Pondicherry. Their office is situated at No.361, Anna Salai, Chennai 18. The building is known as Lekha Pariksha Bhavan.

3. In both the Writ Petitions the challenge is to the demand notices dated 12. 2003 and 13. 20004 issued by the respondent City Municipal Corporation, Chennai, demanding property tax from the petitioner Establishment for the various half years set out therein. A consequential direction is also sought for directing the Corporation to refund a sum of Rs.41,61,550/-which has been illegally collected from the petitioner. The Writ Petitions were admitted on 29. 2005 and notice was ordered to the respondent. Pending the Writ Petitions, this Court granted an interim injunction on the same date. Despite notice on the Writ Petitions, the respondent Corporation had not filed any counter affidavit resisting the claim made by the petitioner.

4. Mr.T. Ravikumar, learned counsel for the petitioner stated that the petitioner is Central Government Establishment and it is constitutionally protected under Article 285 of the Constitution of