JUDGMENT : Sangeet Lodha, J. By way of this writ petition, the petitioner has questioned legality of the assessment order passed by the Taxation Officer determining the liability of tax, surcharge and penalty payable on the vehicles owned by the petitioner-society and the demand notice issued pursuant thereto, under the provisions of Rajasthan Motor Vehicle Taxation Act, 1951 (for short "the Act"). 2. The petitioner, a society registered under the Rajasthan Societies Registration Act, 1958 (for short "the Act of 1958"), constituted with the sole object to run the school for extending education to the children and their overall development, owns certain vehicles which are exclusively used for carrying the children to their school and home. The educational institution run by the petitioner-society is recognized by the Department of Education, Government of Rajasthan. 3. The State Government vide notification dated 21.7.93 issued in exercise of the power conferred by sub-section (1) of Section 3 of the Act, exempted the motor vehicles exclusively used for carrying the children to and from the school, by the educational institutions recognized by the State Government or the educational institutions registered under the provisions of the Act of 1958, from payment of tax under the provisions of the Act. Thereafter, the Commissioner, Transport, vide office order dated 31.3.08/1.4.08 clarified that the vehicles with the sitting capacity 8 or more owned by recognized educational institutions, exclusively used for carrying the children to and from the school shall be registered in 'P' series and are exempted from payment of tax in terms of notification dated 21.7.93 issued by the State Government. 4. The petitioner-society owns a vehicle TATA ACE-Magic bearing registration No.RJ22-PA-0911, having sitting capacity of 8, which is exclusively used for transportation of the children to and from the school run by the petitioner-society. The vehicle stands duly registered as 'Children Vehicle' vide certificate dated 5.8.08 issued by the Secretary, Regional Transport Authority, Pali. 5. All of a sudden, in July,2012, the respondent no.2 refused to renew the fitness certificate of the vehicle, which became due on 30.7.12, allegedly on account of non payment of the tax due. The petitioner-society was served with the order dated 17.8.12 passed by the Taxation Officer assessing the liability of tax, surcharge and penalty payable on the vehicle owned by it. The petitioner-society was served with the order dated 17.8.12 passed by the Taxation Officer assessing the liability of tax, surcharge and penalty payable on the vehicle owned by it. Pursuant thereto, the petitioner-society was served with a demand notice, directing it to make payment of the amount due quantified at Rs.73,083/-. Hence, this petition. 6. Learned counsel for the petitioner submitted that the notification dated 21.7.13 unconditionally extends benefit of exemption from payment of tax under the Act to all such vehicles which are owned by the educational institutions recognized by the State Government or the societies registered under the Act of 1958 and used for transportation of students and therefore, the order impugned passed by the Taxation Officer creating the liability of tax, surcharge and penalty is ex facie without jurisdiction. Learned counsel submitted that clause (g) of Rule 28 of the Motor Vehicle Taxation Rules, 1951 (for short "the Rules of 1951"), which provides for total exemption from liability to taxation in respect of any motor vehicle with the capacity more than 9 excluding the driver owned by and used solely for the purpose of any educational institution, which is recognized by the Government or whose Managing Committee is a society registered under the Act of 1958, has no application in the matter inasmuch as, the exemption extended vide notification dated 21.7.93 is much wider and the provisions incorporated in the Rules of 1951 as aforesaid, cannot have overriding effect over the same. Learned counsel submitted that the order impugned has been passed by the Taxation Officer without giving an opportunity of hearing to the petitioner, which is apparently violative of principles of natural justice. 7. On the other hand, the Deputy Government Counsel appearing for the respondents submitted that by way of notification dated 26.7.01, Rule 28(g) of the Rules of 1951 was amended and the benefit of exemption from payment of tax stands restricted to the motor vehicles with the sitting capacity more than 9 excluding driver and since the petitioner's vehicle is having sitting capacity 8, the benefit of exemption from payment of tax is not available in respect of the said vehicle. Learned counsel submitted that the position in this regard stands clarified by the Commissioner, Transport, vide order dated 19.7.14 and therefore, the order passed by the Taxation Officer assessing the liability of tax, surcharge and penalty and the demand notice issued pursuant thereto, does not suffer from any infirmity or illegality so as to warrant interference by this court in exercise of its extra ordinary jurisdiction under Article 226 of the Constitution of India. 8. I have considered the rival submissions and perused the material on record. 9. Indisputably, as per the provisions of Section 3 of the Act, the State Government is empowered to exempt either totally or partially any motor vehicle or class of vehicles from payment of tax imposed by the Act. Further, sub-section (2) of Section 3 of the Act provides that every notification issued under Section 3, shall be laid before the House of the State Legislature at the session thereof next following and shall be liable to be rescinded or modified by a resolution of that House and the rescission or modification so made, shall, after publication by notification in the Official Gazette be deemed to have come into force. 10. It is to be noticed that the notification dated 21.7.93 exempting the vehicles exclusively used for carrying the students to and from the schools run by the educational institutions recognized by the Government of Rajasthan or run by the societies registered under the Act from payment of tax under the Act, stands duly published in the Rajasthan Gazette dated 22.7.93. It is not the case of the respondents that the notification issued as aforesaid has been rescinded or modified by the House of the State Legislature in terms of provisions of sub-section (2) of Section 3 of the Act. As a matter of fact, the fact that the notification issued by the State Government being in force is not even disputed by the learned Deputy Government Counsel appearing on behalf of the respondents. 11. It is well settled that where a statute requires to do a particular thing in particular manner, the thing must be done in that manner or not at all. All other methods or mode of performance are impliedly and necessarily forbidden. 11. It is well settled that where a statute requires to do a particular thing in particular manner, the thing must be done in that manner or not at all. All other methods or mode of performance are impliedly and necessarily forbidden. In this regard, apart from the decisions cited by the learned counsel for the writ petitioner the reliance may be placed on the decisions in 'Taylor v. Taylor', (1876) 1 Ch.D.426, 'Deep Chand v. State of Rajasthan', AIR 1961 SC 1527 and 'State of U.P. v. Singhara Singh & Ors.', AIR 1994 SC 358. In this view of the matter, any motor vehicle or class of motor vehicles may be exempted from payment of tax payable under the Act, by the State Government either totally or partially only in the manner prescribed under the provisions of Section 3 of the Act and all other methods are impliedly forbidden. 12. Coming to Rule 28(g) of the Rules of 1951, it is true that as per Rule 28(g) as amended vide notification dated 26.7.01, any motor vehicle with the sitting capacity more than 9 excluding driver, owned by and used solely for the purposes of any educational institution, which is recognized by the Government or whose Managing Committee is a society registered under the Act of 1958, is exempted from payment of tax imposed under the Act. But then, it is pertinent to note that the exemption in terms of Rule 28(g), is extended to the motor vehicles of category specified used by the institution covered by the said rule solely for the purpose of educational institution and the benefit under the said Rules is not restricted to the motor vehicles of the category specified used by such educational institutions, for carrying the children to and from the school. Suffice it to say that the class of the vehicles exempted from payment of tax vide notification dated 21.7.93 and the class of the vehicles covered under Rule 28(g) of the Rules is different. In any case, Rule 28(g) of the Rules of 1951, does not and cannot in any manner supercede or override the exemption granted by the State Government vide notification dated 21.7.93 issued in exercise of power conferred by Section 3 of the Act. 13. In any case, Rule 28(g) of the Rules of 1951, does not and cannot in any manner supercede or override the exemption granted by the State Government vide notification dated 21.7.93 issued in exercise of power conferred by Section 3 of the Act. 13. As a matter of fact, while exercising Rules making power under Section 22 of the Act for carrying into effect the purposes of the Act in general and for regulating the method of determination, payment and recovery of tax and the manner in which exemption from and refund of tax may be claimed and granted [Section 22 (2) (e) & (f)], the State Government is not empowered to frame the Rules, which supercede/override the notification issued by the State Government in exercise of the power conferred under Section 3 of the Act, exempting either totally or partially any motor vehicle or class of motor vehicles from payment of tax imposed under the Act. 14. In view of the discussion above, the order impugned passed by the Taxation Officer assessing the liability of tax, surcharge and penalty in respect of the vehicle which stands exempted from payment of tax by virtue of notification dated 21.7.93 issued by the State Government in exercise of the power conferred under Section 3 of the Act is ex facie without jurisdiction. 15. In the result, the petition succeeds, it is hereby allowed. The order impugned dated 17.8.12 passed by the Taxation Officer and the demand notice issued pursuant thereto, are quashed. No order as to costs. Petition Allowed.