ORDER :

In this writ petition, the petitioner has challenged the impugned demand notice dated 27.09.2017 of the second respondent seeking to demand a differential privilege fee of Rs.16,00,000/- from the petitioner for the period between 2014-2015 and 2017-2018.

2. The demand proceeds on the premises that the Chennai City Corporation was expanded by a notification G.O.Ms.No.97, Municipal Administration and Water Supply (Election), dated 19.07.2011 under Section 45(1) of Chennai City Municipal Corporation Act, 1919 and since there was a short payment and collection of privilege fee from the petitioner for the aforesaid period, the petitioner was liable to pay same.

3. The impugned demand is challenged by the petitioner primarily on the ground that the aforesaid notification vide G.O.Ms.No.97, Municipal Administration and Water Supply (Election), dated 19.07.2011 was issued for a limited purpose to delineate the electoral constituencies for election of the councillors and that the said notification did not permit the respondents herein to alter the revenue divisions for collection o