Heard both sides.

2. The petitioner is the Managing Trustee of Merit Educational Charitable Trust cum Principal of Merit Matriculation School, Ambasamudram, Tirunelveli District. It is an unaided educational institution run by the said Trust and the Matriculation school is imparting education to 200 students studying in that school. The school has constructed buildings namely Block A to E and Door No.1 was allotted to the buildings and the respondent Municipality issued demand notice and the said notification, dated 05.10.2007 was issued for collecting the property tax for buildings owned by the petitioner's Institution and the same is challenged in this writ petition.

3. It is stated in the affidavit that the petitioner's Institution buildings are used for educational purpose and therefore, as per section 83(c) of the Tamil Nadu District Municipalities Act, such buildings are exempted from the property tax and hence, the respondent cannot levy any property tax for those buildings.

4. The respondent filed a counter stating that the petitioner is not entitled to claim any exemption and they are not imparting education as a Charitable Trust and they are collecting huge fee