Judgment :- J.B. Koshy, J. appellants/ petitioners question the order of rectification passed by Ext. P5 regarding building tax under S.15 of the Kerala Building Tax Act, 1975 (in short "The Act'). Petitioners along with two others purchased the property by four separate registered sale deeds and constructed a single building with different portions, partitioned between themselves for convenient sake and claimed for separate assessment under the Act. assessments were made in 1987. The orders of assessment were given and petitioners/ appellants paid the amount also. Thereafter, on 8.5.1989 and 19.5.1989 notices were issued for rectification under S.15 of the Act and finally by Ext. P5 dated 4.8.1994 order of rectification was made after seven years of the original assessment. According to the appellants, the order of rectification is time barred in view of the decision in George v. Tahsildar (1992 (2) KLT 690). It is also submitted that rectification order treating the building as single one goes to the basis of the matter and it will amount to reassessment and it is not merely a rectification. The appellants had relied on the Division Bench decision of this Court in Kurian George v. Tahsildar (1995 (2) KLT 457). 2. First we may go through the first contention raised by the appellants regarding question of limitation. S.15 of the Act reads as follows: "15. Rectification of mistake: (1) The appellate authority or the revisional authority may, at any time within three years from the date of an order passed by it on appeal or revision, as the case may be, and the assessing authority may, at any time within three years from the date of any assessment or order passed by it, of its own motion, rectify any mistake apparent from the record of the appeal, revision, assessment or order, as the case may be, and shall, within the like period, rectify any such mistake which has been brought to its notice by an assessee: A plain reading of S.15 shows that an order of assessment can be rectified by the assessing authority or the appellate authority or the revisional authority within three years from the date of respective orders passed by them suo mote by themselves and within three years the assessee also can bring notice of a mistake and then also apparent mistake can be rectified. But time for rectification is maximum three years and after three years it cannot be rectified, even if rectification is necessary. Only an apparent mistake on the face of record can be rectified that too within the time contemplated in the section. Here admittedly seven years have passed after the original assessment and, therefore, limitation under S.15 is applicable in this case and the rectification order is time barred. This is precisely held in the decision reported in George v. Tahsildar (1992 (2) KLT 690) wherein it was held that rectification of a mistake should be done within three years. 3. The learned Government Pleader submits that since the notice of rectification was issued within three years, the question of limitation will not be applicable here. Learned Government Pleader relied on the Division Bench decision in T.D. Davis v. State of Kerala (1997 KLJ Tax Cases 112). There the Division Bench was considering S.19 of the Sales Tax Act wherein it is provided that when an assessee escaped tax, the assessing authority can within five years from the expiry of the year to which the fax relates can proceed to re-determine the tax payable. On the basis of the words used in the section, this Court held that proceedings need only be started within five years. Here the wording is entirely different. Here it has been very clearly stated that authority 'may rectify' any mistake apparent on the record within three years from the date of order and shall rectify any such mistake within such period if it is brought to the notice and mere notice or starting of proceedings is not enough. 4. As held in Cape Brandy Syndicate v.1.R.C. (1921 (1) KB 64) in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used. Since the pecuniary burden is being placed on the assessee, the taxing statute has to be strictly considered. See A.U. Fernandez v. State of Kerala (AIR 1957 SC 657), Mathuram Agrawal v. State of M.P. (1999 (2) SCC 667) and Mahamood v. Tahsildar (2000 (2) KLT 820). One can only look fairly at the language used. Since the pecuniary burden is being placed on the assessee, the taxing statute has to be strictly considered. See A.U. Fernandez v. State of Kerala (AIR 1957 SC 657), Mathuram Agrawal v. State of M.P. (1999 (2) SCC 667) and Mahamood v. Tahsildar (2000 (2) KLT 820). We agree with the decision of this Court in George v. Tahsildar (1992 (2) KLT 690). In S.15 for rectification of mistakes it is very clearly stated that rectification should be done within three years and mere issuance of notice within three years of the date of order sought to be rectified is not enough. Therefore, we are of opinion that rectification order issued after seven years is barred by limitation even though notice for rectification was issued before the expiry of three years from the date of original order. There may be substance in the contention of the appellants that what was done by Ext. P5 is actually not rectification of a mistake apparent on the face of record but a reassessment itself. But in view of the finding that rectification itself is time barred, we are not examining that point in detail. 5. In view of the circumstances, since the rectification order Ext. P5 is beyond the period of limitation, Ext. P5 order and consequential demand Ext. P6 are set aside. However, we note that in the original assessment first floor was not assessed at all. Since assessment of building tax in respect of the first floor was not done, we make it clear that the authorities are free to assess the first floor of the building according to law. The Writ Appeal is allowed.