Discretionary urban land tax exemption depends on specific application, undue hardship, and supporting material, not charity status alone.

Exemption from urban land tax under Section 27 of the Tamil Nadu Urban Land Tax Act, 1966 is discretionary and depends on the Government being satisfied that payment would cause undue hardship. It requires a specific application supported by material and does not arise automatically from charitable status or recognition under the Income-tax Act. The distinction between Section 27, which is discretionary, and Section 29, which operates by force of statute, was emphasised. The trust's recognition under Section 12A(a) did not create a retrospective entitlement for the years in question, and the authorities could consider the government orders then in force. The exemption claim therefore failed.

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Issues: Whether the appellant-trust was entitled to exemption from urban land tax for the relevant period under Section 27 of the Tamil Nadu Urban Land Tax Act, 1966 on the basis of the government orders and its charitable status under the Income-tax Act, and whether the later government order could be relied upon in deciding the exemption claim.

Analysis: Exemption under Section 27 is not automatic. It depends on the Government being satisfied that payment of urban land tax would cause undue hardship and the power is to be exercised on a specific application supported by material. The statutory exemption scheme under Section 29 stands on a different footing, because it operates by force of the statute, whereas Section 27 is discretionary. The appellant had no specific application for exemption before the Government for the relevant period and no recommendation of the Empowered Committee was shown. The trust's recognition under Section 12A(a) of the Income-tax Act, 1961 did not by itself confer exemption from urban land tax, and the recognition order was not available retrospectively for the years in question. The authorities were also entitled to consider the existing government orders in force when the application was decided.

Conclusion: The appellant was not entitled to exemption from payment of urban land tax.

Ratio Decidendi: Exemption under Section 27 of the Tamil Nadu Urban Land Tax Act, 1966 is a discretionary relief based on proven undue hardship and a specific application with supporting material, and charitable recognition under the Income-tax Act does not by itself create a right to such exemption.

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