JUDGMENT Kausik Chanda, J. - This appeal is directed against a judgment and order dated May 03, 2017, passed by the learned Single Judge setting aside the demands for permission fee and licence fee under Sections 202 and 203 of the Kolkata Municipal Corporation Act, 1980 (hereinafter referred to as "the Act") raised by the Kolkata Municipal Corporation (hereinafter referred to as "the Corporation") against the writ petitioner-respondents ("writ petitioners" for short). 2. The writ petitioners carry on business of providing mobile telephone service to consumers, inter alia, within the municipal limits of the Corporation. The Corporation by a letter dated February 09, 2009, raised a demand against the writ petitioners for payment of Rs.6,960/- on account of licence fee and advertisement tax under Sections 203 and 204 of the Act respectively in respect of glow signs displayed by the writ petitioners. Again, by two letters dated February 23, 2009 and May 18, 2009 the Corporation further raised demands of Rs. 15,18,123/- and Rs. 24,46,409/-, respectively, for permission fee under Section 202, licence fee under Section 203 and advertisement tax under Section 204 of the Act for display of glow signs. 3. The writ petitioners prayed before the learned Single Judge for a declaration that the Corporation was not competent in law to demand any licence fee or permission fee and also prayed for quashing the demands for such permission fee and licence fee. 4. By the order impugned, the learned Single Judge disposed of the writ petition directing, inter alia, as follows:- "The hoardings and glow signs put in a property belonging to an individual and not visible to a member of the public from a public road is not chargeable by the Corporation. Moreover, as noted above, Section 203 does not allow the authority to levy any licence fee. On the concept of quid pro quo, it is observed that, the Corporation authorities are required to do certain things under Section 203. That would entail some cost. However, the Corporation authorities are taking trade licence fee. The Corporation authorities are, therefore, at liberty to factor in the cost involved in the exercise under the guidelines while considering the fee applicable for obtaining a trade licence. "In view of the discussions above, the demands for licence or permission fees for the glow signs made against the petitioner are set aside. The Corporation authorities are, therefore, at liberty to factor in the cost involved in the exercise under the guidelines while considering the fee applicable for obtaining a trade licence. "In view of the discussions above, the demands for licence or permission fees for the glow signs made against the petitioner are set aside. The prayer for compensation made in the writ petition was not pressed at the hearing." 5. Before this court, the Corporation and the writ petitioners are adidem that in view of the judgment reported at ( Calcutta Soft Drinks Private Limited -vs- Calcutta Municipal Corporation, (2007) AIR Calcutta 136 ) which has been subsequently affirmed by the Supreme Court by a judgment and order dated July 10, 2019, passed in Civil Appeal No.4639 of 2009 (Calcutta Municipal Corporation -vs- Calcutta Soft Drinks Pvt. Ltd), the writ petitioners are exempted from levy of tax under Section 204 of the Act. The Corporation has drawn attention to the Kolkata Municipal Corporation (Amendment) Act, 2019 whereby the Section 204 of the Act has been omitted as a whole. However, the legality and validity of the demands for permission fee under Section 202 and licence fee under Section 203 of the Act have been seriously defended by the appellants. 6. The appellants assail the judgment and order impugned on the ground that, though Section 202 provides that an application for such permission should be accompanied by a security deposit and does not provide for any permission fee to be paid, Section 543 of the Act authorises the Corporation to ask for a permission fee. The Corporation traces its power to impose such fee to Section 543(2) of the Act in absence of a specific provision for the same. 7. The Corporation urges that the learned Single Judge fell into error in holding that Section 203 of the Act did not allow the Corporation to levy any licence fee. The Corporation refers to sub section (3) of Section 203 of the Act and submits that the said proviso clearly empowers the Corporation to levy licence fees as may be determined by the Corporation by regulation or in its budget estimates. The Corporation refers to sub section (3) of Section 203 of the Act and submits that the said proviso clearly empowers the Corporation to levy licence fees as may be determined by the Corporation by regulation or in its budget estimates. The Corporation emphasises on the word "occupier" as occurring in sub section (1) of Section 203 of the Act to suggest that it is the advertiser who is in occupation of a site where any advertisement is displayed and as such the obligation to obtain a licence and pay any fees therefor, lies on the advertiser. 8. The Corporation further submits that permission fees and licence fees are distinct and different imposts. Permission fee is levied against an advertisement while the licence fee is levied against the site where the advertisement is displayed. Therefore, the grant of permission and the grant of licence are two separate and distinct charging events and the Corporation is entitled to impose permission fees as well as licence fees separately. 9. By referring to the policy guidelines framed by the Corporation on the display of advertisements within the Corporation area, it has been submitted that in view of the regulatory functions carried out by the Corporation with regard to advertisements and the sites used for display of such advertisements, the Corporation is entitled to levy permission fees and licence fees as well. It is the case of the Corporation that the company did not obtain any licence or permission as required under the Act for display of its advertisements. 10. On behalf of the writ petitioners it has been submitted that Chapter XIV of the Act is required to be read harmoniously. Section 202 prohibits the display of any advertisement without a written permission therefor from the Municipal Commissioner. Section 203 provides for the grant of a licence and payment of licence fees, while Section 204 imposes a tax on an advertisement. There is no provision in Section 202 for payment of any fee or levy like in the other two Sections. The writ petitioners argue that Section 543 (2) cannot be invoked by the Corporation to impose a permission fee as the scheme of the Chapter XIV of the Act makes it clear that it was never the intention of the law-makers to impose such a fee. The writ petitioners argue that Section 543 (2) cannot be invoked by the Corporation to impose a permission fee as the scheme of the Chapter XIV of the Act makes it clear that it was never the intention of the law-makers to impose such a fee. The Corporation is attempting to illegally extract levy from the writ petitioners in the name of permission fees, since it has been debarred from realizing tax under Section 204 by judicial pronouncements. Referring to the Kolkata Municipal Corporation (Amendment) Act, 2019, it has been submitted that by amending Sections 202 and 203 and omitting Section 204 altogether, the legislature has provided for a singular impost, namely, a permission fee for advertisement. 11. The writ petitioners submit that the legislature has brought in the said amendment to remove the ambiguity and flaw in the earlier regime as it was never intended to impose permission fee under Section 202 of the Act against the same advertisement which had been taxed under Section 204 of the Act. The writ petitioners rely upon a judgment reported at ( State of Bihar -vs- S. K. Roy, (1966) AIR SC 1995 ) for the proposition that in dealing with matters of construction, subsequent legislation may be looked at in order to see what is the proper interpretation to be put upon the earlier provision where the earlier provision was obscure or ambiguous or readily capable of more than one interpretation. The writ petitioners suggest that the unamended provisions of Chapter XIV of the Act being ambiguous, the interpretation that favours the writ petitioners should be resorted to. 12. It is further contended that obtaining a licence for the use of a particular site to display an advertisement is a condition precedent for obtaining a permission as per Section 202(2)(a) of the Act. The grant of licence, therefore, is a part of the permission. There is no real distinction between permission and licence and, by enumerating two counts, the Corporation is making different claims for the same thing. 13. With regard to licence fees, it has been submitted by the writ petitioners that the Corporation may be entitled to impose a fee for licence under Section 203, of the Act but the writ petitioners, being the advertiser, cannot be made liable for such payment. 13. With regard to licence fees, it has been submitted by the writ petitioners that the Corporation may be entitled to impose a fee for licence under Section 203, of the Act but the writ petitioners, being the advertiser, cannot be made liable for such payment. It has been strenuously argued by referring to sub-section (1) of Section 203 that it is the owner of the site who requires to obtain a licence for display of advertisement and make the payment of the fee therefor. Placing reliance upon sub-section (3) of Section 204 of the Act, it has been submitted that a licensee may be authorised to collect and pay the tax on advertisement subject to deduction of five per cent to be kept by him as collection charges in respect of an advertisement displayed. The proviso makes it clear that the licensee under Section 203 is different from the advertiser. 14. The writ petitioners further suggest that as per Sections 208 and 208A of the Act, if any advertisement is displayed in contravention of the provisions of the Act, the owner or the occupier of the land, building, wall, hoarding, frame, post, kiosk or structure has been made liable for taking down or removal of such advertisement. Since no liability has been attached to the advertiser in the aforesaid Sections, the advertiser cannot be said to be obliged to obtain licence or be made liable for non-payment of the licence fee. 15. The writ petitioners place reliance upon the budget estimates adopted for the year 2006 2007 to show that permission fee under Section 202 as well as the licence fee under Section 203 has been fixed on per square feet basis upon advertisements. Such impost partakes the character of a tax. Such nature of levy, having no nexus with the service rendered, is liable to be struck down. 16. The writ petitioners rely upon the Paragraphs 45, 46, 47 and 48 of the judgment reported at ( Commissioner, Hindu Religious Endowments -vs- Sri lakshmindra Thirtha Swamiar of Sri Shirur Mutt, (1954) SCR 1005 ) to contend that since a fee is in return for or in consideration of services rendered, it is necessary that the levy of a fee should be corelated to the expenses incurred by the Government in rendering the services. 17. The judgment reported at ( Calcutta Municipal Corpn. 17. The judgment reported at ( Calcutta Municipal Corpn. -vs- Shrey Mercantile (P) Ltd., (2005) 4 SCC 245 ), has been relied upon by the writ petitioners to contend that where the Government intends to raise revenue as the primary object, the imposition is a tax. In the garb of regulation, any fee or levy which has no connection with the costs or expenses for administering the regulation, cannot be imposed and only such levy can be justified which can be treated as a part of regulatory measure. 18. Before dealing with the rival submissions raised at the Bar, it may be necessary to reiterate the well-known principle that there are three components of a levy in statute, namely, the subject of the levy; the person liable to pay the levy and the rate of the levy. The controversy in this appeal revolves around the question as to what are the subjects of levy and who are the persons liable for levy under Sections 202 and 203 of the Act and, most importantly, the legislative competence to impose such levy. 19. To appreciate the controversy, the relevant parts of Sections 202 and 203 of the Act, are quoted below: "202. Prohibition of advertisements without written permission of the Municipal Commissioner. (1) No person shall erect, exhibit, fix or retain upon or over any land, building, wall, hoarding, frame, post, kiosk or structure any advertisement, or display any advertisement to public view in any manner whatsoever, visible from a public street or public place (including any advertisement exhibited by means of cinematograph), in any place within Kolkata without the written permission of the Municipal Commissioner. Provided that the permission under this sub-section shall be accorded subject to the submission of written consent, in original, of the owner or the authority of land, building, wall, hoarding, frame, post, kiosk or structure upon or over which the advertisement has been proposed to be erected, exhibited, fixed or retained, by the person intending to erect, exhibit, fix or retain any advertisement, or display any advertisement to public view: Provided further that application for permission under this sub-section shall accompany a declaration by the advertiser stipulating a time-frame within which the advertisement shall be erased, removed or taken down: Provided also that the application for permission shall also accompany a security deposit of such amount, as may be determined by the Corporation, by order, which shall, if the advertisement is not erased, removed or taken down by the advertiser within seven days after the expiry of the time-frame for erasure, removal or taken down of such advertisement as mentioned in the declaration, be deemed to have been forfeited and the money, as forfeited, shall be used by the Municipal Commissioner for erasure, removal or taken down of the advertisement: Provided also that when the advertisement is erased, removed or taken down within seven days after the expiry of the time-frame in the declaration, the security deposit shall forthwith be refunded. (2) The Municipal Commissioner shall not grant such permission if- (a) a licence for the use of the particular site for purpose of advertisement has not been taken out, or (b) the advertisement contravenes any provisions of this Act or the rules or the regulations made thereunder, or (c) the tax, if any, due in respect of the advertisement has not been paid, (d) the May-in-Council, on the basis of the recommendation of the Heritage Conservation Committee, is of the view that such advertisement will obstruct the view of, or destabilise the structure of, or will not be in harmony with, any heritage building." "203. Licence for use of site for purpose of advertisement. Licence for use of site for purpose of advertisement. (1) Except under and in conformity with the terms and conditions of a licence, no person being the owner, lessee, sublessee, occupier or an advertising agent shall use or allow to be used any site in any land, building, wall or erect or allow to be erected on any site, any hoarding, frame, post, kiosk, structure, neon sign or sky-sign for the purpose of display of any advertisement. (2) For the purpose of advertisement, every person (a) using any site before the commencement of this Act, within ninety days from the date of such commencement, or (b) intending to use any site, or (c) whose licence for use of any site is about to expire, shall apply for a licence or renewal of a licence, as the case may be, to the Municipal Commissioner in such form as may be specified by the Corporation. (3) The Municipal Commissioner shall, after making such inspection as may be necessary and within thirty days of the receipt of the application, grant, refuse, renew or cancel a licence, as the case may be, on payment of such fees as may be determined by the Corporation by regulations or as the budget estimate shall state under sub-section (3) of Section 131. (4) The Municipal Commissioner may, if in his opinion the proposed site for any advertisement is unsuitable from the considerations of public safety, traffic hazards aesthetic design, or obstruction of the view of, or harmony with, any heritage building, refuse a licence or refuse to renew any existing licence. (5) Every licence shall be for a period of one year except in case of sites used for temporary fairs, exhibitions, sports events or cultural or social programmes. (7) The Municipal Commissioner shall cause to be maintained a register wherein the licences issued under this section shall be separately recorded in respect of advertisement sites (a) on telephone, telegraph, tram, electric or other posts or poles erected on or along public or private streets or public places, (b) in lands or buildings, (c) in cinema halls, theatres or other places of public resort." 20. A bare perusal of Section 202 of the Act makes it clear that permission from the Corporation is necessary for display of any advertisement in the municipal area. Permission fee therefore, is required to be paid against the advertisement. A bare perusal of Section 202 of the Act makes it clear that permission from the Corporation is necessary for display of any advertisement in the municipal area. Permission fee therefore, is required to be paid against the advertisement. In other words, the subject of levy under Section 202 is the advertisement. It has not been disputed by the writ petitioners that it is the advertiser who is liable to obtain permission for display of such advertisement. All that has been contended is that no fees are leviable for such permission. 21. On the other hand, it will be evident that the subject of the licence under Section 203 of the Act is the "site". Sub-section (1) read with subsection (7) of Section 203 of the Act implies that "site" would mean any land, building or wall which has been used for display of advertisement or any place or thing where any hoarding, frame, post, kiosk, structure, neonsign or sky-sign is erected for display of advertisement. 22. The answer to the question as to who is the person liable to obtain a licence can be traced to sub-section (2) of Section 203. As per the said provision, it is every person "using any site" or "intending to use any site" or a licence holder whose licence is about to expire, who needs to obtain a licence for display of advertisement. 23. The legislature deliberately did not define the user to make it flexible and open for the Corporation to accept licence fee from anyone who may be liable to obtain licence by dint of any agreement or arrangement between the person and persons associated with the display of advertisement. A user can be a person or persons as indicated in sub-section (1) of 203, it can also be the advertiser himself or its franchisee or dealer. The obligation to obtain a licence may depend upon the mutual understanding or agreement amongst the owner, lessee, sub-lessee of the site, advertiser, advertising agent, franchisee or dealer of the advertiser as the case may be. 24. The obligation to obtain a licence and the payment of fees, however, must be seen in the light of Section 207 of the Act which runs as follows: "207. Presumption in case of contravention. 24. The obligation to obtain a licence and the payment of fees, however, must be seen in the light of Section 207 of the Act which runs as follows: "207. Presumption in case of contravention. Where any advertisement has been erected, exhibited, fixed or retained upon or over any land, building, wall, hoarding, frame, post, kiosk or structure or displayed to public view from a public street or public place in contravention of the provisions of this Act or any regulations made thereunder, it shall be presumed, unless the contrary is proved, that the contravention has been committed by the person or persons on whose behalf the advertisement purports to be or the agents of such person or persons." 25. A conjoint reading of Sections 203(2) and 207 of the Act makes it clear that the Corporation, in absence of any contrary documents or evidence, will levy licence fee upon the advertiser only. 26. Therefore, no exception can be taken to the impugned notices of demand directed against the writ petitioners unless the writ petitioners show contrary by virtue of any agreement or otherwise. 27. To justify the imposition of permission fee as well as licence fee upon the writ petitioners, it is the case of the Corporation that the licence fee has been charged against a site and permission fee has been charged against the advertisements. Such stand, though appearing to be acceptable at the first blush, a scrutiny of the budget estimates for the year 2006 2007 reveal otherwise. The relevant part of the budget estimates is reproduced below:- PERMISSION FEE U/S 202(1) Rate for 2006-2007 (a) (i) Non-illuminated advertisement on Hoarding/Post/Kiosks/Frame/Structure etc. Upto 200 sq.ft. Above 200 sq.ft. (ii) For lighted advt. on Hoarding/wall/post/Kiosk/Frame/Struc ture etc. (iii) For illuminated/backlit on -do- (c) Advertisement on vehicles (Board carried/painting etc.) (d) Advertisement on Glowsign board fixed onpremises (only top of the shop, within 50 sqft.) (o) Mobile hoarding or hoardings mounted on vehicles (lighted/non-lighted), area of display being within 300 sqft., u/S 202, 203 & 204 + LUC Rs.17/-per sq. ft. per year or part thereof Rs.28/- per sq. ft. per year or part thereof 50% surcharge over the above rates 100% surcharge over the above rates Rs.35/- per sqft. per year or part thereof Rs.35/- per sqft. ft. per year or part thereof Rs.28/- per sq. ft. per year or part thereof 50% surcharge over the above rates 100% surcharge over the above rates Rs.35/- per sqft. per year or part thereof Rs.35/- per sqft. per year or part thereof Rs.500000/- per vehicle one time in a financial year LICENCE FEES ON ADVERTISEMENT U/S 203(1) Rate for 2006-2007 (per sq.ft.) (a) Non-illuminated/non-lighted Advt. on Hoarding/Kiosks/Structures/Frames etc. (i) upto 200 sq.ft. (ii) Above 200 sq.ft. (b)(i)Lighted Advt. on -Do- (ii)Illuminated/backlit on -Do- (c) Advertisement on Vehicles (d) Glow Sign Boards/fixed on walls of premises (e) Mobile Hoardings of Hoardings mounted on vehicles Rs.11/- per year or part thereof Rs.17/- per year or part thereof 50% surcharge over the above rates 100% surcharge over the above rates Rs.11/- per year or part thereof Rs.11/- per year or part thereof Rs. See the rate chart for permission fee U/s 202 (1). 28. It has already been discussed that the subject of the levy under Section 202 of the Act is an "advertisement" while the subject of the levy under section 203 is the "site" used for the display of the advertisement. It is clear from the said budget estimates that it is the advertisement and the advertisement alone that has been considered first, under Section 202 of the Act for a permission fee and, then again, on account of licence fee under Section 203 at a different rate albeit the advertisement not being the subject of levy under Section 203 of the Act. Therefore, such imposition of levy for advertisement under section 203 of the Act is required to be annulled. 29. It must also be said that though Section 202 of the Act does not provide for permission fee for display of an advertisement, it is lawful for the Corporation to invoke sub-section (2) of Section 543 of the Act to levy such fee. Section 543 (2) of the Act runs as follows:- "543. Signature, conditions, duration, suspension, revocation, etc., of licences and written permissions. Section 543 (2) of the Act runs as follows:- "543. Signature, conditions, duration, suspension, revocation, etc., of licences and written permissions. (2) Except as otherwise provided in the Act or the rules or the regulations made thereunder, for every such licence or written permission a fee may be charged at such rate as may from time to time be fixed by the Municipal Commissioner with the sanction of the Mayor-in-Council, and such fee shall be payable by the person to whom the licence or the written permission is granted". 30. Sub-Section (2) of Section 543 is a repository of the power of the Corporation to impose fee for every licence or permission if not otherwise provided in the Act. Therefore, imposition of permission fee for advertisement under Section 202 of the Act in the relevant budget estimate should be upheld. 31. The next question that arises for consideration is whether the imposition of permission fee proportionate to the size of advertisement makes the levy vulnerable as a "tax". 32. The Supreme Court, in the case reported at ( State of Tamil Nadu vs- TVL. South Indian Sugar Mills Association, (2015) 13 SCC 748 ), noticed a number of earlier decisions which held that the element of quid pro quo in the strict sense is not always a sine qua non for a fee, and all that is necessary is that there should be a reasonable relationship between the levy of a fee and the services rendered. The service to be rendered is not a condition precedent and the same does not lose the character of a fee provided the fee so charged is not excessive. It is also not necessary that the services to be rendered by the collecting authority should be confined to the contributories alone. If the levy is for the benefit of the entire industry, there is sufficient quid pro quo between the levy and the services rendered to the industry as a whole. 33. The object of incorporation of Chapter XIV in the Act was to regulate, control, monitor and impose tax on advertisements other than advertisements in newspapers and on the TV and radio. In fact, all provisions under the said Chapter, including Sections 202 and 203, spell out the regulatory functions to be carried out by the Corporation. 33. The object of incorporation of Chapter XIV in the Act was to regulate, control, monitor and impose tax on advertisements other than advertisements in newspapers and on the TV and radio. In fact, all provisions under the said Chapter, including Sections 202 and 203, spell out the regulatory functions to be carried out by the Corporation. A further set of guidelines on the display of advertisements was introduced by the Corporation with the object to ensure that man-made structures do not conflict with the environment and blend with the surroundings by proper placement and pleasing designs and also to ensure that advertising does not constitute a hazard to the safety and welfare of the public at large. 34. Under the said guidelines, hospitals, nursing homes, educational institutions, libraries, places of worship, cremation grounds, graveyards, government building etc. have been delineated as general nonadvertisement zones. Certain areas, such as the entire Maidan area, Dalhousie Square tank and buildings like Writers' Building, High Court have been identified as specific non-advertisement zones. The advertisements containing nudity, defamatory messages, propagating exploitation of women or child, cruelty to animals, glorifying violence etc, have been banned. The said guidelines also forbid the use of structures for the display of advertisements that obstruct the clear vision of any traffic signal, block access to any building, block the passage of light or circulation of air or cause any other inconvenience of like nature to the public in general. 35. Clause 2.4 of the guidelines and the sub-paragraphs thereunder provide for regulations as to display of advertisements at traffic junctions. Clause 3 makes special provisions for display of advertisements on hoardings. It prescribes the sizes of structural design, erection, height restrictions, in between distance, alignment, projection, display and illumination of hoardings. Under Clause 3.9, 4, 5 and 6 special provisions have been made with regard to hoardings in the vicinity of fly-overs, on bus stops, bridges and business premises. Clause 7 provides special norms for display of advertisements by floating balloons. The procedure for application for permission has been provided in Clause 8. Applications are scrutinized in terms of Clause 8.1.2. Clause 8.1.3 provides for post approval of erection of hoarding subject to compliance with the formalities prescribed thereunder. Clause 8.1.4 of the guidelines provides for right to appeal before the Municipal Commissioner to redress any grievance in relation to the policy guidelines. Applications are scrutinized in terms of Clause 8.1.2. Clause 8.1.3 provides for post approval of erection of hoarding subject to compliance with the formalities prescribed thereunder. Clause 8.1.4 of the guidelines provides for right to appeal before the Municipal Commissioner to redress any grievance in relation to the policy guidelines. Clause 8.2 provides for procedure and formalities for regularization of existing hoarding. Clause 10.1 describes duties and responsibilities of the licence holder agency. 36. Such exhaustive, comprehensive and detailed guidelines indicate the broad and varied extent of regulatory functions undertaken by the Corporation related to display of advertisement. Since the provisions under the Chapter XIV of the Act and the policy guidelines require the Corporation to ensure proper compliance by due diligence and monitoring, the levy for permission and licence are fees and cannot be termed as a tax. The fees being regulatory in nature, element of quid pro quo is not necessary for levying such fee. Such fee, however, should not be extortionist or excessive there should be a nexus between the regulatory service provided and the fee levied. 37. It has been held in the judgment reported at ( Secunderabad Hyderabad Hotel Owners Association -vs- Hyderabad Municipal Corporation, Hyderabad, (1999) 2 SCC 274 ) that fee for trade licence for running lodging houses, hotels, restaurants etc. on the basis of the rent paid was justified. The Supreme Court held as follows:- "16. In the first place it is not necessary that a fee should only be in the form of a lump sum fee. A fee can also be graded as in the present case. The Corporation has chosen the quantum of rent paid as the criterion for the quantum of fee to be charged. The rent under the relevant provisions of law in that connection, does have a nexus with the area in the occupation of the lodging house or eating house. In the case of activities carried on by these lodging houses and eating houses, the area in their possession has a direct nexus with the extent of business activities. The need for cleanliness and hygiene, the generation of garbage and the extent of regulation that may be required depend upon the size of the premises which in turn control the extent of activity. The need for cleanliness and hygiene, the generation of garbage and the extent of regulation that may be required depend upon the size of the premises which in turn control the extent of activity. Undoubtedly in a given case if the premises are old, the rent may be less but that does not mean that classifying premises on the basis of the rent paid has no connection with the quantum of fee charged." 38. It may also be noted that in TVL South Indian Sugar Mills Association (Supra) imposition of regulatory fee on per bulk litre industrial alcohol was not interfered with, though increase of such fee from fifty paisa per bulk litre to one rupee was found to be unjustified. 39. The writ petitioners suggest that the imposition of fee on per squarefoot basis makes the levy a "tax". The nature of the regulatory functions as discussed above, exercised by the Corporation, amply indicate that nature and extent of such regulatory functions have a direct nexus with the dimensions and type of the advertisement. Therefore, no exception can be taken in prescribing permission fee proportionate to the size and type of advertisement. Such fee cannot be termed as a tax simply because the fee has been prescribed on per square-foot basis. 40. The upshot of the discussion as aforesaid may be summarised as follows: (a) Subject of permission fee under Section 202 of the Act is advertisement and such fee can be imposed taking recourse to Section 543(2) of the Act. (b) Subject of licence fee under Section 203 of the act is site for advertisement. "Site" for the purpose of Section 203 of the Act would mean any land, building or wall which has been used for display of advertisement or any place or thing whereupon any hoarding, frame, post, kiosk, structure, neon-sign or sky-sign is erected for display of advertisement. (c) It is the user of the site who is required to obtain a licence under Section 203 of the Act. A user can be a person or persons as indicated in sub-section (1) of Section 203 of the Act or anyone including the advertiser who is associated with the display of advertisements. (d) Unless contrary is shown, it is the advertiser who is primarily responsible for payment of permission fee and license fee. A user can be a person or persons as indicated in sub-section (1) of Section 203 of the Act or anyone including the advertiser who is associated with the display of advertisements. (d) Unless contrary is shown, it is the advertiser who is primarily responsible for payment of permission fee and license fee. (e) Permission fee for display of advertisement is regulatory as well as compensatory by nature and such fee proportionate to size of advertisement does not amount to tax. 41. The legislature in its wisdom thought it fit to amend provisions under Chapter XIV of the Act by Kolkata Municipal Corporation (Amendment) Act, 2019 to levy fees for the advertisements displayed within the Municipal area in a more effective, practical and rational manner. A Court of law, however, need not interpret pre-amended provisions taking aid of the amended provisions if the pre-amended provisions can be interpreted with clarity, avoiding anomaly. The pre- amended provisions under Chapter XIV as discussed above can be reconciled without any ambiguity and construed to make the provisions workable. Therefore, interpretation of the said provisions, as suggested by the writ petitioners in the light of the amended provisions is unwarranted. 42. Accordingly, the impugned demands for licence fees under Section 203 of the Act are set aside and demands for permission fees under Section 202 of the Act are upheld. The order of the learned Single Judge is set aside. APO 351 of 2017 is allowed to the aforesaid extent without any order as to costs. 43. Urgent certified website copies of this judgment, if applied for, be supplied to the parties subject to compliance with all requisite formalities.