( 1 ) THE petitioner, Steel Authority of India, Limited has set up a township for the residence of persons employed in the Bhilai Steel Plant as also for other allied amenities and facilities like schools, markets, hospitals, etc. This township is divided into several sectors. The buildings are owned by the petitioner. In the year 1964, the Madhya Pradesh State Legislature passed an Act known as the "madhya Pradesh Nagariya Sthawar Sampatti Kar Adhiniyam, 1964 (No. 14 of 1964)" (hereinafter referred to as "the Sampatti Kar Adhiniyam"), to apply to all 'urban areas' having population of 10,000 and above according to last census and included within the limits of a local authority and to any other area of commercial or industrial importance having population of ten thousand or above according to the last census. By notification dated 30/01/1967 "bhilai Nagar Industrial Township in Durg District" was declared "urban area" of commercial and industrial importance as defined under S. 2 (h) of the Sampatti Kar Adhiniyam. The buildings and lands falling within the limits of this township were assessed to property tax in exercise of powers under S. 4 of the Sampatti Kar Adhin