The Petitioner is a Trust created under the Declaration of Trust, dated 29.11.1990, with an object to provide medical relief and facilities to the poor and needy irrespective of caste, creed and religion either free of cost or at concessional rates and to others on such terms and conditions, but not for the purpose of profits. Thus, the Trust has been created as a Public Charitable Trust.

2. The petitioner submitted applications to the Government dated 07.01.1991, and dated 25.03.1992, seeking allotment of lands for the purpose of establishing a hospital offering free/concessional medical service to needy and desirous persons. The Government vide G.O.Ms.No.460, Revenue department, dated 10.04.1992, allotted an extent of 2542 sq.mts of land in Anna Nagar, Chennai, for the purpose of setting up of a hospital. Condition was imposed that the hospital should provide free treatment to 30% of the outpatients and 15% of the inpatients belonging to the poor families and 15% of the total beds in the hospitals should be reserved for poor inpatients.

3. The petitioner claims that they have established the hospital and have been running the hospital in accordance with the terms of the conditions imposed by the Government. While so, the first respondent corporation sought to levy property tax on the building with effect from first half year 1992-93, immediately the petitioner addressed a letter to the first respondent on 14.12.1994, pointing out that it is a charitable hospital and therefore, exempted from the levy of property tax in accordance with Section 101(e) of the Chennai City Municipal Corporation Act, 1919 (herein after referred to as the Act). Ultimately, the Corporation appears to have not acceded to the petitioner's request and they were assessed to tax and a demand was issued on 28.03.2002 and another demand on 02.07.2005.

4. The petitioner challenged the proceedings, which ultimately went up to the Taxation Tribunal in TAT No.112/2006 and the petitioner had deposited a sum of Rs.25,35,494/- which is stated to be still in the hands of the respondent Corporation. The appeal was dismissed by the Tribunal by order dated 19.06.2006. Aggrieved over which, the petitioner preferred an appeal before the Principal Judge, City Civil Court in MTA No.21 of 2006. The said appeal was allowed by judgment, dated 27.08.2007 and the matter was remanded back to the first respondent for considering the issue of eligibility of the petitioner for exemption under Section 101(e) of the Act. After such remand, the first respondent passed an order, dated 12.08.2008, refusing to grant exemption, which was challenged by the petitioner in W.P.No.21084 of 2008 as being a cryptic order. The said writ petition was allowed by order dated 28.08.2008 with a direction to the first respondent to reconsider the matter on merits and pass fresh orders within a time frame. Once again, the claim for exemption was rejected, by order dated 27.01.2009, which was challenged by the petitioner in W.P.2383 of 2009 and the said Writ Petition was allowed by order dated 12.01.2015, directing the first respondent to examine the claim for exemption in accordance with the judgment in MTA No.21 of 2006. Pursuant to the said order, the second respondent by communication dated 19.03.2015, directed the petitioner to appear for a personal hearing with all records. The petitioner is stated to have appeared before the second respondent on 06.04.2015, during which the petitioner was asked for the list of beneficiaries for the year 2014-15, which were furnished by the petitioner on 21.04.2015, followed by a further representation, dated 23.04.2015, enclosing photographs etc. The petitioner vide their letter dated 04.05.2015, enclosed a copy of the trust deed and the order of exemption granted under the Income Tax Act, 1961. Thereupon, the second respondent adjourned the enquiry to 11.05.2015, which was cancelled and re-fixed on 23.06.2015, to examine the list of beneficiaries and the pe