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14. Learned counsel, thus, contended that in case the charge or an additional charge is not created within 3 years of the notice for change of rateable value, the respondent Corporation would have no right to issue the demand bill on the increased rateable value. Thus, the limitation is 3 years which would get enlarged only if the charge is created within that period, since there cannot be enlargement of time if there is no time limit fixed.

15. Learned counsel also referred to the judgment of the Full Bench in Municipal Corporation of Delhi v. M/s. Palace Cinema & Anr, 2nd (1972) I Delhi 163 where the matter in issue was the advertisement tax under Section 142 of the Act. It was held that the recovery of taxes which are and can be imposed by the Corporation under Section 113 of the Act being provided for in Sections 152 to 162 of the Act, is not covered by Section 455 and, therefore, the proviso fixing the period of 3 years for recovery cannot be called in aid to contend that the recovery of advertisement tax for any period in the case was barred by time.

(d) Under provisions of Section 124 a list under sub-section (1) is first prepared. Objections are invited to the said list under sub-section (3) by a public notice and if land and building is going to be assessed for the first time, or if rateable value is proposed to be increased, then individual notices have to be given to the owners or to the lessees or occupiers of the land or building.
(e) When notice is issued under Section 124(3) objections can be filed to the same under Section 124(4). These objections are to be enquired into and investigated, and only after they are to be disposed off, can the assessment list be authenticated under Section 124(6) of the Act. If no objections are filed then again the list prepared under Section 124(1) can be authenticated under Section 124(6). It is only thereafter that tax would become payable.
(f) Section 125 provides that the list authenticated under Section 124(6) shall be conclusive subject to such alterations which may be made thereto under Section 126 or as a result of any appeal which may be filed against the authenticated list.
(g) Under Section 126 the amendment in the assessment list for the current year can only be made after deciding the objections which may be filed to the notice issued under Section 126(1). Thereafter the liability to pay tax would arise.

A full bench of this Court in the case of Lok Kalyan Samiti vs. Municipal Corporation of Delhi was concerned with a case where notice under Section 126 had been issued and an increased rateable value was proposed. This increased rateable value was thereafter indicated in the list for the subsequent years which were prepared under Section 124 of the Act. One of the questions which arose for consideration before the full bench was as to whether the assessment list for the subsequent years could be modified after the disposal of objections under Section 126 or not. At page 197 of the report, it was observed by this court as :-

27. I am, thus, unable to accept the contention of the learned counsel for the petitioner that the proceedings have to be completed or the bill has to be issued within 3 years of issuance of the notice for increase of the rateable value. The cause of action cannot be stated to have arisen from the date of issuance of the notice, but would arise only after the assessment order is passed. The issuance of the demand or the bill would create a charge on the property, which will have to be issued within 3 years of authentication of the assessment list which can only occur on the assessment order being passed. The sum would become due only after the assessment order is passed and Section 455 of the Act provides a period of 3 years only after the sum becomes due.