Appeal against tax levy under the Cantonments Act includes exemption claims before the appellate authority.

Section 93 of the Cantonments Act, 2006 permits an appeal not only against assessment but also against the levy of tax itself. On that construction, the appellate authority may examine both the legality of the property tax levy and the appellant's claim to exemption from property tax. The availability of the statutory appeal therefore does not bar consideration of substantive objections on merits, and all available contentions may be urged before the appellate forum.

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Issues: Whether an appeal lies under Section 93 of the Cantonments Act, 2006 against levy of property tax and whether the appellant can raise the plea of exemption from such tax before the appellate authority.

Analysis: Section 93(1) provides for an appeal not only against assessment but also against levy of any tax under the Act. On that construction, the appellate authority is competent to examine the challenge to the levy as well as the contention that the educational institution is entitled to exemption from payment of property tax. The availability of the appellate remedy therefore does not preclude consideration of the appellant's substantive objections.

Conclusion: The appeal remedy under Section 93 is available, and the appellant may urge all available contentions, including exemption from property tax, before the appellate authority.

Final Conclusion: The matter was disposed of by preserving the appellant's right to pursue the statutory appeal and to seek consideration of all objections on merits.

Ratio Decidendi: An appeal under Section 93 of the Cantonments Act, 2006 lies against levy of tax, and the appellate authority can examine both the legality of the levy and any claim to exemption.

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