(Prayer: This Writ Petition filed under Articles 226 of the Constitution of India praying to a) issue of a writ of certiorari or any other appropaite writ, order or Direction quashing the impugned demand notices dated 05.12.2023 and 19.02.2024 issued by Respondent No.1 vide Annexure-A and Annexure-A1 demanding from the petitioner the payment of Rs.59,16,62,516/- (rupees Fifty-Nine Crore Sixteen Lakh Sixty Two Thousand Five Hunred and Sixteen Only) towards arrears of property tax for the Financial Years (Fy) 2010-11 to 2023-24 vide notice dated 05.12.2023 and Rs.13,21,69,214/- (Rupees Thirteen Crore Twenty One Lakh Sixty Nine Thousand Two Hundred And Fourteen Only) towards property tax for Fy 2024-25 vide notice dated 19.02.2024; b) issue a writ of mandamus or any other appropriate writ, order or direction directing respondent No.1 to forthwith issue no dues certificate in respect of the payments made by the petitioner towards the property tax for the Financial Years 2010-11 to 2020-21; C) direct the respondents to produce all records, documents, resolutions, assessment orders, valuation reports and communication relied upon for issuing the impugned demand notices pertaining exclusively to the period post Financial Year 2020-21 including but not limited to resolutions for Assessment and Property Tax Calculation for the said period without reopening revising or in any manner disturbing the property Tax Assessments and Payments Already Concluded Upto Financial Year 2020-21; D) direct the respondents to pay the cost of the petition; e) pass any other orders as this Hon'ble Court may deem appropriate and for this act of kindness the petitioner as in duty bound shall ever pray.)

Oral Order

1. Petitioner is before this Court seeking following reliefs:

          a) Issue of a writ of certiorari or any other appropriate writ, order or direction quashing the impugned demand notices dated 05.12.2023 and 19.02.2024 issued by respondent No.1 vide Annexure-a and Annexure-A1 demanding from the petitioner the payment of Rs.59,16,62,516/- (Rupees Fifty-Nine Crore Sixteen Lakh Sixty Two Thousand Five Hundred And Sixteen Only) towards arrears of property tax for the financial years (FY) 2010-11 to 2023-24 vide notice dated 05.12.2023 and Rs.13,21,69,214/- (Rupees Thirteen Crore Twenty One Lakh Sixty Nine Thousand Two Hundred And Fourteen Only) towards property tax for FY 2024-25 vide notice dated 19.02.2024;

          b) Issue a writ of mandamus or any other appropriate writ, order or direction directing respondent no.1 to forthwith issue no dues certificate in respect of the payments made by the petitioner towards the property tax for the financial years 2010-11 to 2020-21;

          c) direct the respondents to produce all records, documents, resolutions, assessment orders, valuation reports and communication relied upon for issuing the impugned demand notices pertaining exclusively to the period post financial year 2020-21 including but not limited to resolutions for assessment and property tax calculation for the said period without reopening revising or in any manner disturbing the property tax assessments and payments already concluded upto financial year 2020-21;

          d) Direct the respondents to pay the cost of the petition;

          e) Pass any other orders as this Hon'ble Court may deem appropriate and for this act of kindness the petitioner as in duty bound shall ever pray.

2. By impugned notices dated 15.12.2025 and 19.02.2024 produced at Annexures-A and A1, the respondent-Municipal Corporation has called upon the petitioner to pay a sum of Rs.59,16,62,516/- and Rs.13,21,69,214/- towards property tax with a further direction of which action would be initiated in terms of Section 142(a) and 145(c) of the Municipalities Act, 1964.

3. Learned Senior Counsel Sri Harish Narasappa appearing for petitioner through video conference referring to the documents filed along with a memo dated 18.12.2025, brings to the attention of this Court that as against the demand raised by the respondent No.1 upto the years 2010-2011 to 2021-2022 vide notice dated 16.11.2022, the petitioner has fully paid and satisfied the demand. He submits that notwithstanding the payment as above, the respondent-authorities have been issuing multiple notices without divulging the details enabling the petitioner to understand and assess the basis of the demands so made. He also refers to Karnataka Municipalities and Certain Other Law (Amendment) Act, 2024 specifically with reference to amendment to Section 105 of the Municipalities Act, 1964, which provides for insertion in sub-section (3) of Section 105 which reads as under :

          "Notwithstanding anything contained in this sub- section the assessment made under this sub-section for any return submitted under sub-section (1) for the last 6 financial years, commencing for the financial year 2023-2024 shall be concluded within 1 year."

4. Referring to the same, he submits that the said statutory provision operates as a bar to the respondents to stake any claim beyond the period contemplated thereunder. Therefore, he submits that the impugned notices at Annexures-A and A1 calling upon the petitioner to pay such a huge sum of money, without providing the details as to the period to which they pertain is arbitrary and unsustainable.

5. In response, Sri Amaresh S.Roja, learned counsel for respondent-Corporation submits that the documents now furnished by the petitioner along with the memo would be treated as an assessment under Section 105 of the Municipalities Act, 1964 and after affording sufficient opportunity to the petitioner, appropriate orders will be passed in accordance with law.

6. Heard. Perused the records.

7. The impugned notice at Annexure-A calling upon the petitioner to pay a sum of Rs.59,16,62,516/- purportedly pertains to the years 2010-11 to 2023-24. While impugned notice at Annexure-A1 calling upon the petitioner to pay Rs.13,21,69,214/- pertains to the year 2024-25.

8. In the light of submission made and the documents furnished on behalf of the petitioner to indicate that the demand made by the respondent-authorities as of the year 2021-22 purportedly having been paid by the petitioner, the demand now made in Annexure-A for the period prior to the said payment, requires reconsideration.

9. As fairly submitted by learned counsel Sri Amaresh S.Roja, appearing for respondent No.1 and also keeping in mind the submission made by learned Senior counsel appearing for the petitioner particularly with reference to the amendment effected to Section 105 of the Municipalities Act, this Court deems it appropriate to remand the matter to the concerned Chief Officer of respondent No.1 with following directions :

          (i) Writ petition is partly allowed;

          (ii) The Chief Officer shall first furnish the details based on which the impugned notices have been issued at Annexures-A and A1 to the petitioner within 15 days from the date of receipt of the certified copy of the order. Thereupon the petitioner shall file its response along with the documents supporting their claim of they having been paid the taxes upto 2021- 2022.

          (iii) Local inspection, if any required for the purpose of assessment and determination of the property tax shall be conducted with the prior notice and in presence of authorized representatives of petitioner.

          (iv) Such exercise shall be undertaken and appropriate orders strictly in accordance with law shall be passed by the concerned Chief Officer within an outer limit of 3 months after petitioner submitting its response as directed above.

          (v) All contentions including the question of limitation for the purpose of assessment of property tax are kept open to be urged before the concerned Chief Officer.

          (vi) It is made clear, till such order is passed the respondent No.1-twon municipal shall not take any precipitative action pursuant to the demand notices at Annexures-A and A1 subject matter of this petition.

          (vii) It is further made clear that no opinion is expressed in this order on merits of the matter. The Chief Officer shall assess and pass appropriate orders on the merits of the case without being influenced in any manner whatsoever by disposal of this writ petition.