G. P. Singh, C. J.-

l. This order shall also dispose of Mise Petition No.191 of 1974 (Abdul Gaffar and others v. The Administrator, Indore Municipal Corporation and another).

2. By these petitions under Article 226 of the Constitution, the petitioners challenge the imposition of tax on advertisements other than advertisements published in newspapers under section 132 (2) (1) of the Madhya Pradesh Municipal Corporation Act, ) 956 by the Indore Corporation.

3. The main contention urged by the learned counsel for the petitioners is that the resolution imposing the tax did not contain any "system of assessment" as required by section 133 of the Act. The impugned tax was imposed by the order of the Administrator dated 7th September 1970. Section 132 enumerates the taxes which can be imposed by the Corporation, A tax on advertisements other than advertisements published in newspapers is one of the taxes which the Corporation can impose under the Act. The procedure of imposition of taxes is contained in section 133. Sub section (1) of section 133. provides that the Corporation may at a special meeting bring forward Appellant resolution to propose the imposition of any tax under section 132 defining the class of persons or description of property proposed to be taxed. The amount or rate of tax to be imposed and the system of assessment to be adopted. The argument of the learned counsel for the petitioners is that the expression "system of assessment" means the entire procedure for assessment and collection of tax and that as the order of the Administrator did not contain any procedure for assessment or collection of the tax, there was noncompliance of the mandatory requirement of section 133 and the imposition was invalid. In our opinion, the argument is not sound. A reading of section 133 will show that it merely deals with the procedure for imposition of tax. The procedure for assessment, collection, remission refund and recovery of taxes, cesses; etc. is provided by the byelaws which can be made by the Corporation under section 427 (3) of the Act. Now in the intention of the Legislature was to provide for the procedure for assessment and collection of taxes in section 133 itself, there was no point in making a separate provision for framing byelaws for assessment, collection, etc. of taxes under section 427 (3). The expression "system of assessment" as used in section 133, in our opinion, means the stage of imposition of the tax and not other stages as a whole which are relevant for assessment or collection of tax. This view is strongly supported by a decision of the Supreme Court in Vallabhdas v. Municipal Committee. Akola AIR 1967 SC 133, In this case the Supreme Court construed section 67 (2) of the Central Provinces and Berar Municipalities Act, 1922 which required a Municipal Committee to publish in accordance with rules a notice defining the class of persons or description of property proposed to be taxed, the amount or rate of tax to be imposed and the system of assessment to be adopted. It was held having regard to other sections in the Act which dealt with rules for assessment and collection of tax that the expression "system of assessment" in section 67 (2) was limited to the stage of the imposition of the tax and that it was sufficient if the notice referred to in that section mentioned the stage of imposition, the goods, property or persons to be taxed and the rate or rates at which they were to be taxed. Section 67 (2) of the Central Provinces and Berar Municipalities Act. 1922 was in pari materia with section 133 (1) of the Madhya Pradesh Municipal Corporation Act, 1956. Vallabhdas's ease, therefore, has full application here. System of assessment referred to in section 133 must, in our opinion, be restricted to the stage of imposition and it cannot be construed to include the entire procedure for assessment and collection of tax for which separate provision is made by the Act under section 427 (3). A reading of the