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Issues: Whether the deeming provision in Section 7(3) of the M.P. Krishi Upaj Mandi Adhiniyam, 1973, which states that every market committee shall be deemed to be a local authority for all purposes, extends to exemption from property tax under Section 6(a)(iii) of the M.P. Nagariya Sthawar Sampatti Kar Adhiniyam, 1964.
Analysis: The expression "for all purposes" in Section 7(3) was construed in the context of the 1973 Act and its scheme. The non obstante clause was held not to confer a general status of local authority for every statute irrespective of context, but to operate for purposes under the 1973 Act and for matters relatable to that enactment. The Court held that the words could not be treated as surplusage, yet they also could not be read so widely as to override the 1964 tax exemption scheme beyond the intended field of operation.
Conclusion: The market committee was not a local authority for the purpose of exemption from property tax under the 1964 Act, and the levy of property tax was upheld.