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Issues: Whether an alteration in the municipal assessment list under section 123 of the Maharashtra Municipalities Act can take effect so as to enhance property tax for a year or part of a year that has already expired.
Analysis: The relevant provisions were treated as materially similar to section 82 of the Bombay Municipal Boroughs Act, 1925. The governing principle adopted was that the official year is the unit of taxation for municipal property tax, and an amendment to the assessment list becomes effective for tax purposes only if made during the currency of that official year. Once the assessment year has ended, a later alteration cannot be used to impose enhanced liability retrospectively for that expired year.
Conclusion: The alteration in the assessment list could not operate retrospectively for the expired official year, and the challenge to the demand failed.
Final Conclusion: Municipal property tax could be enhanced only within the current official year, not for a period already concluded.
Ratio Decidendi: For municipal property tax, the official year is the unit of levy, and an amendment to the assessment list must be made during that official year to be effective for that year.