JUDGMENT : ( 1. ) BY this petition under Article 226 of the Constitution, the petitioner seeks quashing of the order Annexure A-11 passed by the additional Property Tax Commissioner in revision as also other orders passed by the Assistant Property Tax Commissioner and the Property Tax Officer, assessing and demanding property tax from the petitioner in respect of the years 1966-67, 1967-68 and 1968-69. ( 2. ) THE petitioner is a Government company. The petitioner owns Bhilai Steel Plant in Bhilai. The petitioner has its mines and mining colonies at Rajhara and Jharandalli. The Property Tax Officer on 24th May 1969 demanded property tax for the years 1966-67, 1967-68 and 1968-69 in respect of lands and buildings in Bhilai Nagar and Rajhara and Jharandalli mining colonies. The petitioner filed a revision which was decided against the petitioner by the Assistant Property Tax Commissioner by his order dated 24th December 1969. The petitioners contention in that appeal was that the notification applying the Madhya Pradesh Nagariya Sthawar Sampatti kar Adhiniyam 1964, to Bhilai Nagar Industrial Township and Rajhara Jharandalli mining colony was vague and, therefore, it could not be given effect to It was also contended that the lands in Rajhara-Jharandalli mining colony vested in the Central Government and were exempt from taxation under section 6 of the Act. Both these contentions were negatived by the assistant Property Tax Commissioner, The view taken by the Assistant property Tax Commissioner was that the area in 15 villages mentioned in annexure R-4 was included in Bhilai Nagar industrial township and was covered by the notification. It was also held that the petitioner was liable for payment of property tax in respect of the land in Rajhara-Jharandalli mining colony because it was using that kind for mining purposes. The petitioner filed a revision which was decided by the Additional Property Tax commissioner by his order dated 7th October 1971. The aforesaid contentions were repeated before the Additional Property Tax Commissioner and were rejected. The Additional Property Tax Commissioner, however, differed from the Assistant Property Tax Commissioner with respect to the area which could be included within Bhilai Nagar industrial township. According to the Additional Property Tax Commissioner, 43 villages were included in this township. ( 3. ) THE learned counsel for the petitioner has raised the same contentions before us which were raised before the Additional Property Tax Commissioner. ( 4. According to the Additional Property Tax Commissioner, 43 villages were included in this township. ( 3. ) THE learned counsel for the petitioner has raised the same contentions before us which were raised before the Additional Property Tax Commissioner. ( 4. ) SECTION 1 (4) of the Act provides that it shall apply to all urban areas having population of ten thousand and above according to last census which the State Government shall by notification specify. Section 2 (h)defines "urban area" to mean the area comprised within the limits of a local authority and any other area of commercial or industrial importance having population of ten thousand or above according to last census. By notification dated 20th January 1967 the State Government specified "bhilai Nagar industrial Township in Durg District" and "rajhara-Jharandalli (Mining colony) in Durg District" as urban areas of commercial and industrial importance for the purposes of section 1 (4) of the Act. The learned counsel for the petitioner has argued that it is not possible to make out as to how many villages or as to what area is included within Bhilai Nagar industrial township and Rajhara-Jharandalli mining colony. ( 5. ) THE Deputy Advocate General who appears for the respondent has produced before us the District Census Handbook of 1961 for Durg District. bhilai Nagar town is mentioned at page 390 of this Handbook. The area of Bhilai Nagar twon as specified at page 390 is 25,687. 74 acres. The population of Bhilai Nagar is shown to be 86,116. The entries at page 390 further show that Bhilai Nagar town described therein comprised of Circles 1 to 28 and Chhawni cluster. The learned Deputy Advocate General, however, is unable to point out as to what villages are included in Circles 1 to 28. Without knowing as to what villages are included in these circles, it is not possible to understand as to what specific area is included in Bhilai Nagar town. The case was adjourned from time to time to enable the respondents to explain to us the meaning of the circles referred to at page 390 of the Handbook. The respondents, however, have failed to produce any material or to refer to any book relating to census which may disclose as to how these circles have to be understood. The case was adjourned from time to time to enable the respondents to explain to us the meaning of the circles referred to at page 390 of the Handbook. The respondents, however, have failed to produce any material or to refer to any book relating to census which may disclose as to how these circles have to be understood. Even assuming, therefore, that "bhilai nagar industrial township", mentioned in the notification issued by the State government under section 1 (4) is the same as Bhilai Nagar town referred to at page 390 in the Handbook, we are unable to delineate the area comprised within Bhilai Nagar industrial township. As the area within this description cannot be found out, the notification cannot be given effect to. We may here point out that throughout the proceedings taken against the petitioner the authorities were indefinite as to what villages or what area is included in bhilai Nagar industrial township. The Additional Property Tax Commissioner, however, thought that 43 villages are included. The return shows that 24 villages are included. The return refers to a letter of the Tahsildar according to which only 13 villages are included. In the state of this confusion and without knowing as to what villages are included in the circles referred to at page 390 of the Census Handbook, we are constrained to reach the conclusion that the notification applying the Act to Bhilai Nagar industrial township cannot be given effect to. ( 6. ) AS regards the application of the Act to Rajhara-Jharandalli mining colony, it is at least clear that villages Rajhara and Jharandalli in which mining operations are carried on fall within this description. There is, therefore, no difficulty in holding that the Act has been extended to the area included in Rajhara and Jharandalli villages. The petitioners buildings in these villages, in our opinion, would be covered by the provisions of the Act and the petitioner would be liable for payment of property-tax in respect of all its buildings in these villages. The learned counsel for the petitioner, however, contends that the petitioner has been taxed not only in respect of buildings but also in respect of open land which did not in relevant years belong to the petitioner but was vested in the Central Government. The learned counsel for the petitioner, however, contends that the petitioner has been taxed not only in respect of buildings but also in respect of open land which did not in relevant years belong to the petitioner but was vested in the Central Government. We have already mentioned that the Assistant Property Tax Commissioner was of the opinion that the petitioner was liable to pay property tax in respect of the lands in Rajhara and Jharandalli villages because it was using the lands for its purposes. Mere user does not make the petitioner liable for payment of property tax. The lands in these villages were acquired by the Central government. They were assigned to the petitioner by a deed of assignment on 27th March 1978. Before this date the lands in these two villages clearly vested in the Central Government and were exempt from taxation under article 285 of the Constitution and the section 6 of the Act. ( 7. ) THE petition is allowed. The impugned order (Annexure A-11)passed by the Additional Property Tax Commissioner and orders of the Assistant Property Tax Commissioner and the Property Tax Officer relating to the assessment of property tax for the years 1966-67, 1967-68 and 1968-69 are quashed except in so far as they relate to the imposition of tax on the petitioners buildings situated in Rajhara and Jharandalli. There shall be no order as to costs. The security amount deposited by the petitioner shall be refunded to it. Petition allowed.