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Issues: Whether the notice issued for amendment of the assessment list under Section 67 of the Punjab Municipal Act, 1911 was vague and unsupported by material, and whether the resultant enhancement of property tax could be sustained.
Analysis: The statutory scheme governing assessment and further amendment of an assessment list requires that the Committee specify the ground on which amendment is proposed, give the affected person meaningful notice, and afford an opportunity to object. A notice that does not clearly disclose whether the proposed action is based on omission, erroneous valuation, fraud, accident, mistake, or any other definite ground does not satisfy the statutory requirement or the principles of natural justice. The record also did not disclose any primary material supporting the alleged increase in the godown capacity or the rate adopted for assessment. The amendment, appellate affirmation, and the State Government's order were therefore unsupported by relevant material and suffered from lack of application of mind.
Conclusion: The notice and the consequential enhancement of assessment were unsustainable, and the assessee succeeded.