Writ maintainability and standard-rent basis govern municipal property-tax valuation; defective assessments were quashed and remanded.

Alternative remedy did not bar writ jurisdiction where municipal property-tax assessments were alleged to be without jurisdiction or contrary to binding law, so the High Court entertained the petitions. Annual value of the flats could not be fixed mechanically by adopting the purchase price; it had to be determined on the standard-rent basis under the applicable rent-control framework and municipal law, taking the relevant land and construction cost into account. Because the assessments and resulting demands were not made in conformity with settled legal principles, they were quashed and the matter was remitted for fresh determination in accordance with law and Supreme Court directions.

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Issues: (i) Whether a writ petition was maintainable against municipal property-tax demands despite the availability of statutory remedies; (ii) whether annual value of the flats could be determined by reference to the purchase price of the flats and the standard-rent principle; (iii) whether the impugned assessments and demands were liable to be set aside and the matter remitted for fresh decision.

Issue (i): Whether a writ petition was maintainable against municipal property-tax demands despite the availability of statutory remedies.

Analysis: The availability of an alternative remedy does not operate as an absolute bar to writ jurisdiction. Where the assessment is alleged to have been made without jurisdiction, in violation of binding legal principles, or where the issue raised is substantially one of law, the High Court may entertain the petition under Article 226 of the Constitution of India. The long pendency of the matter after issuance of rule also weighed against refusal of relief on the ground of remedy.

Conclusion: The writ petitions were maintainable.

Issue (ii): Whether annual value of the flats could be determined by reference to the purchase price of the flats and the standard-rent principle.

Analysis: Annual value had to be worked out in accordance with the standard-rent framework under Section 6 of the Delhi Rent Control Act and the governing municipal provision. The purchase price of a flat was not a safe or complete measure by itself because it may include builder's profit. The proper method was to ascertain the cost of land at the relevant time, estimate construction cost if necessary, and then determine the reasonable gross annual rent from that composite basis.

Conclusion: The purchase price alone could not be treated as the basis for assessment, and annual value had to be determined on the standard-rent principle.

Issue (iii): Whether the impugned assessments and demands were liable to be set aside and the matter remitted for fresh decision.

Analysis: The assessments were found not to have been made in conformity with the binding decisions governing fixation of standard rent and annual value. As the assessing authority had not followed the settled legal position and the demands flowed from those defective assessments, the impugned orders could not stand. Fresh consideration by the assessing authority was necessary in accordance with the controlling Supreme Court directions.

Conclusion: The assessments and demands were set aside and the matter was remitted for fresh determination.

Final Conclusion: The petitions succeeded, the municipal assessments and consequential demands were quashed, and the assessing authority was directed to reconsider the matter afresh in accordance with law and the governing Supreme Court decisions.

Ratio Decidendi: In municipal property-tax assessment, alternative remedy does not bar writ jurisdiction where the assessment is without jurisdiction or contrary to binding law, and annual value must be determined on the legally relevant standard-rent basis rather than by mechanically adopting the purchase price of the property.

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