RANDHIR SINGH, J. :- This is a reference made by the Additional District Magistrate (Judicial) of Lucknow under S. 162, U. P. Municipalities Act.

2. The Union Government has quite a number of buildings which are in the use of the Northern Railway in the City of Lucknow and the Municipal Board of Lucknow used to levy house and water taxes on these buildings. The last revision of assessment was made in the year 1948 and it appears that taxes were paid in respect of these buildings till 31-3-1953. A fresh assessment became due in 1953, and it is in connection with this assessment that a dispute arose between the Municipal Board and the Railway Authorities managing the property sought to be assessed, about the liability for payment of tax.

3. A brief history of the previous revision of assessment made in 1948 may be useful in appreciating the points in dispute. On 1-10-1947, the Municipal Board revised the basis of the assessment of taxes and adopted a system popularly known as slab system of levy of taxes. This was opposed by the Railway Authorities, as it resulted in an increase in the taxes and a reference was made to the District Judge of Lucknow, Dr. L.N. Misra, under S. 13