JUDGMENT K. CHANDRU, J. Heard the argument of both sides and perused the records. 2. The petitioner is a registered Society with Registration No. 6 of 1948. A Scheme Decree has also been framed in respect of the Soceity in O.S. No. 13 of 1942 by the sub-ordinate Judge, Tirunelveli. The petitioner is also claiming that it has been registered as a Public Charitable Trust with the Income Tax Department. The petitioner owns several urban properties situated in various urban centers and rural areas in Madurai, Tirunelveli and Tuticorin Districts. 3. The Tamil Nadu Urban Land Tax,1966 (for short 'ULT' Act) was enacted with a view to levy tax on Urban Lands in the State of Tamil Nadu. It was brought into effect from 1.7.1963 for the City of Chennai. Subsequently, it was made applicable to other Municipal Towns by various Government's Notifications. 4. The petitioner Association applied for an exemption under Section 27(1) of the ULT Act, which reads as follows: "27. Power of Government to exempt or reduce urban land tax: (1) The Government, is satisfied that the payment of urban land tax in respect of any class of urban lands or by any class of persons will cause undue hardship, they may, subject to such rules as may be made in this behalf, by order- (a) exempt such lands or persons from the payment of urban land tax; or (b) reduce the amount of such urban land tax whether prospectively or retrospectively." 5. When the State Government notified in the year 1991 the extension of the Act to Thoothukudi and Palani, the petitioner Association paid Urban Land Tax in respect of properties in Tuticorin and Palani. Subsequently, they made an application dated 18.3.1996 seeking for an exemption from the ULT Act in respect of the properties at Thoothukudi. They also relied upon the order of the Government granting exemption from the ULT Act granted in respect of their properties at Madurai which was granted in terms of G.O. Ms. No. 307, Revenue Department dated 15.2.1978. 6. Pursuant to the application made certain details were sought for by the respondents from the petitioner Association. They also had benefit of an interim order for some time on certain condition, pending decision on the exemption request by the Government. No. 307, Revenue Department dated 15.2.1978. 6. Pursuant to the application made certain details were sought for by the respondents from the petitioner Association. They also had benefit of an interim order for some time on certain condition, pending decision on the exemption request by the Government. Unlike the exemption granted under Section 29 of the ULT Act, the exemption granted under Section 27(1) is liable to be cancelled or modified by the Government at any time. In order to exercise the power under Section 27, the Government had issued certain guidelines from time-to-time. Some of the orders issued by the Government in this regard are as follows: (i) G.O. Ms. No. 3526, Revenue dated 15.6.1973 (ii) G.O. Ms. No. 1947, Revenue dated 17.9.1976 (iii) G.O. Ms. No. 2910, Revenue dated 29.10.1983 7. By G.O. Ms. No. 1947 dated 17.9.1976, the Government also constituted an "Empowered Committee" to examine and to make recommendations to Government regarding cases for granting exemption in terms of Section 27(1) of the ULT Act. The composition of the committee is as follows: "1. Chief Secretary to Government …..Chairman 2. Member of the Board of Revenue in charge of the subject "Urban Land Tax" …..Member. 3. Secretary to Government, Finance Department …..Member 4. Secretary to Government, Revenue Department …..Member." The Deputy Secretary to Government in the Revenue Department in charge of the subject 'Urban Land Tax' shall function as the Secretary to the "Empowered Committee." 8. The case of the petitioner was referred to the Empowered Committee. A report was also called from the Commissioner for Land Reforms. It is seen from the records that the Committee noted that the petitioner's is a large institution with lots of properties and wealth. The urban land tax payable by them was very negligible compared to the annual income of the Association and it has capacity to pay the tax. They are also charging rent for properties in Survey Nos. 20 and 24 and therefore, there will be no economic hardship for the Association to pay the urban land tax. 9. The first respondent State based on this report by G.O.(per) No. 270, Revenue dated 2.6.2004 rejected the request for the grant of exemption under Section 27(1) of the ULT Act. It is this order which is under challenge in this writ petition. 9. The first respondent State based on this report by G.O.(per) No. 270, Revenue dated 2.6.2004 rejected the request for the grant of exemption under Section 27(1) of the ULT Act. It is this order which is under challenge in this writ petition. Pending the writ petition, the petitioner association got an interim order from paying the tax in respect of its properties in Thothukudi and Palani. 10. K. Srinivasan, learned counsel for the petitioner submitted that the order of the State Government was arbitrary and liable to be interfered with by this Court. He also relied upon certain decisions of this Court and of the Supreme Court in support of his submissions. The learned counsel pressed into service the following decisions: 12. (1988) 2 LW 289. (Madras High Court) 13. (1997) 2 MLJ 419 : (1997) 2 LW 867. (Madras High Court) 14. (2000) 1 LW 596 . (Madras High Court) 15. (2005) 3 MLJ 133 : (2005) 2 CTC 2(SC) 11. In the Mouna Mutt, Rock Fort, Tiruchirappalli by its hereditary Trustee Adheenam Srila-Sri Shankugha Desiga Gnanasambanda Paramacharya Swamigal Avargal, Dharmapuram, Thanjavur District v. Asst.Commissioner, Urban Land Tax, Trichirapally and Another (supra), this Court was concerned as to whether the guidelines framed under G.O. Ms.1947 dated 17.9.1976 was correctly applied in the case of the petitioner in that case. Since there was non-application of mind by the authorities, the matter was remitted back to Government for fresh consideration. 12. In the second decision in Venkatachala Mudaliar Trust by its Managing Trustee v. Special Commissioner and Commissioner of Land Reforms, Chepauk, Asst.Commissioner, Urban Land Tax (West), Coimbatore and Collection Tahsildar, Urban Land Tax, Coimbatore (supra), this Court was considered the exemption of certain lands from the purview of the urban land tax and it has no relevance to the present case on hand. 13. In the third decision, the Division Bench of this Court rejected the stand of the Trust for a complete exemption under Section 29(h) and got a direction for the grant of exemption in terms of Section 27(1) of the Act, as it was found utilising 90% of the net income for the charitable purposes. The said case do not help the case of the petitioner. 14. The said case do not help the case of the petitioner. 14. In the fourth decision, the Supreme Court was considering the case of a Trust which challenged the order of the Division Bench of this Court made in W.A. No. 1190 of 1999. The Division Bench of this Court in the said Appeal recorded the following finding in upholding the order of the Government in negativing the request of the appellant Turst. The order of the Division Bench reads as follows: "Heard both sides. In an enquiry initiated at the instance of the appellant, who has claimed exemption from payment of Urban Land Tax it has been found that the appellant does not satisfy the guidelines mentioned in G.O. Ms. No. 1843 Revenue dated 29.10.1983 for claiming exemption as prayed for. It has been found that the appellant trust does not satisfy the claim that it has to spend 90% of its income for charitable purposes. It has only spent 9.9% and 49.55 of its net income for the said objectives. Inter alia it has further been found that the whole extent of the lands of the appellant are used for running cinema theatre, saw mill, godowns the same are let out for commercialized residential purposes and they truly derives a large income from the lands and no piece of land is used for charitable purposes. Moreover no evidence has been produced by the appellant to show that the income of the trust is spent for the charitable purposes. The aforesaid finding of the 1st respondent has been affirmed by the learned single Judge in the writ petition. We do not find any irregularity or illegality in the finding of the learned single Judge and the same does not call for any interference in the present appeal. Present appeal, in the circumstances, is dismissed. Consequently, C.M.P. No. 11716 of 1999 is also dismissed." (emphasis added) 15. When the said decision was appealed to the Supreme Court, it affirmed the order of the Division Bench and dismissed the Appeal. While doing so, in para: 17, it observed as follows: " 17. While under Section 29, the exemption is granted by the statue itself and is automatic in respect of the urban lands owned by the authorities or institutions referred to therein, the exemption under Section 27 is not so. While doing so, in para: 17, it observed as follows: " 17. While under Section 29, the exemption is granted by the statue itself and is automatic in respect of the urban lands owned by the authorities or institutions referred to therein, the exemption under Section 27 is not so. For exemption under Section 27, power is vested with the State Government to exempt the lands or persons from payment of tax "if the Government is satisfied that the payment of urban land tax.... would cause undue hardship." Such power can be exercised by the Government only on specific application by the person or institution seeking exemption and on placing satisfactory material for exercise of such power. The exemption under Section 27 is not a matter of right and does not follow as a matter of course." (emphasis added) 16. In the light of the survey of the legal precedents cited at the bar and taking note of the relevant provision regarding exemption found in the ULT Act, the following propositions emerge. (a) The exemption under Section 27 is not a matter of right and does not follow as a matter of course. (b) For the purpose getting exemption under Section 27, the party must show undue hardship in paying the urban land tax. (c) Since no rule has been framed under Section 27(1), the Government guidelines will have to be followed. (d) The Government guidelines provides the formation of an 'Empowered Committee' consisting of higher officers of the Government and their views are to be considered by the Government. 17. If the reasons found in the impugned order are tested in the light of the above propositions, then no fault can be found in the order. Before passing the impugned order the Government had considered all relevant circumstances and also they were armed with report of the Empowered Committee as well as the opinion of the Commissioner of Land Reforms. Since the petitioner has failed to prove any undue hardship the impugned order does not suffer from any infirmities and illegalities. 18. In this context, it is also relevant to point out the word of caution given by the Supreme Court in exercising judicial review over discretionary orders of the State. The Supreme Court in AIR 1988 SC 1681 : (1988) 4 SCC 364 , in paragraph 30 has observed as follows: "30..... 18. In this context, it is also relevant to point out the word of caution given by the Supreme Court in exercising judicial review over discretionary orders of the State. The Supreme Court in AIR 1988 SC 1681 : (1988) 4 SCC 364 , in paragraph 30 has observed as follows: "30..... In the ultimate analysis, the present trend of judicial opinion in England on the question as to whether a 'prerogative' power is reviewable or not depends on whether its subject matter is suitable for judicial control. All that we need is to end this part of the judgment by extracting the cautionary note administered by H.W.R.WADE in his ADMINISTRATIVE LAW, 5th edn. at p. 352 in these words; On the one hand, where Parliament confers upon some minister or other authority to be used in discretion, it is obvious that the discretion ought to be that of the designated authority and not that of the Court. Whether the discretion is exercised prudently or imprudently, the authority's word is to be law and the remedy is to be politically only. On the other hand, Parliament cannot be supposed to have intended that the power should be open to serious abuse. It must have assumed that the designated authority would act properly and responsibility, with a view to doing what was best in the public interest and most consistent with the policy of the statue. It is from this presumption that the Courts take their warrant to impose legal bounds on even the most extensive discretion." 19. In the light of the above, the challenge to the impugned order fails. Accordingly, the writ petition stands dismissed. No costs. The connected miscellaneous petition is also dismissed. Writ petition dismissed.