JUDGMENT : P.M. MANOJ, J. The above writ petition is preferred being aggrieved by the issuance of Exts. P5 and P6 series of orders of assessments and notices of demand, respectively, under the Kerala Building Tax Act 1975 (Act 7 of 1975). 2. The petitioner is the Secretary of an Association that owns and manages the following educational institutions located in Kothamangalam: An Engineering College in the Aided sector. An Arts College in the Aided sector. An International School following the ICIC mode of instructions. 3. It is stated, Section 3(1)(b) of the Kerala Building Tax Act, 1975 (the Act) exempts buildings principally used for educational purposes from building tax. This exemption encompasses the hostels and canteen facilities attached to the college and school, which the petitioner argues are essential for the core function of the institutions. However, the statutory authorities levied a tax on these facilities pursuant to Section 5 of the Act. 4. Ext.P1 reveals that the petitioner association secured an exemption from the government in 2010, coinciding with the construction and establishment of the indoor stadium and ladies' hostel attached to the Arts College. This exemption was granted in recognition of the fact that the aforementioned buildings are principally used for educational purposes. Notably, the third respondent himself issued a communication to the government, certifying that the indoor stadium and ladies' hostel qualified for exemption under the Act. 5. In the course of development activities, the petitioner association constructed three ladies' hostels for the engineering college, a postgraduate hostel and canteen for the arts college, and a hostel attached to the international school between 1995 and 2013. These facilities were built using the association's own funds supplemented by grants from statutory central bodies. All the aforementioned buildings are exclusively used for educational purposes. However, the third respondent, the designated authority under the Act, initiated proceedings against these six hostels and the canteen pursuant to the Act. This commenced with a Ext.P3 notice dated 07.02.2015 issued by the Village Officer, Kothamangalam, on behalf of the third respondent. The petitioner responded to this notice with a letter dated 25.02.2015. Subsequently, the third respondent served the petitioner with Ext. P4 series of notices dated 16.12.2016, and 901.2017. These notices, issued under Sections 9(2) / 9(4) of the Act, directed the petitioner's representative to appear before the third respondent on a specified date to produce specific documents. 6. The petitioner responded to this notice with a letter dated 25.02.2015. Subsequently, the third respondent served the petitioner with Ext. P4 series of notices dated 16.12.2016, and 901.2017. These notices, issued under Sections 9(2) / 9(4) of the Act, directed the petitioner's representative to appear before the third respondent on a specified date to produce specific documents. 6. Following this, the petitioner association designated a qualified representative to appear before the third respondent on 10.01.2017, to present their defence. This representative adequately presented the case of the petitioner, supported by relevant documentation, to the officer designated by the third respondent for this purpose, not before the Tahsildar. Notwithstanding this representation, the third respondent proceeded with an assessment under Section 9 of the Act. Subsequently, the petitioner was served with the Ext. P5 series assessment orders and the corresponding Ext. P6 series demand notices. It is an admitted fact that the petitioner association did not respond to these notices and assessment orders at that time. 7. In light of these circumstances, the petitioner approached the assessing authority, challenging the applicability of Section 3 of the Act and referencing Ext. P1 government order, which grants exemptions for the indoor stadium, stage, green room, and playground under the aforementioned statutory provision. However, the order also states that all previously granted exemptions are subject to the decision of the Supreme Court in Civil Appeal No. 207 of 2012. Based on these assertions, the petitioner approached the statutory authority to withdraw the proceedings in consideration of the arguments presented in Ext. P7 objection. 8. In response, the petitioner received Ext. P8 communication, which stated that they had failed to appear for a hearing and produce sufficient documentation contesting the levy of tax. The communication further explained that the assessment of the buildings was conducted under the direction of the government and initiated by the Land Revenue Commissioner, to assess the buildings that are not assessed from 1973, with a report submitted upon completion of assessment. However, the petitioner was not granted a proper opportunity to present their arguments during this assessment process. Ext.P8 concluded by advising the petitioner to file an appeal under Section 11(1) with the Second Respondent. In compliance, the petitioner filed Exts.P9 and P10 composite appeals against Ext. P7 series demand notices before the second respondent. 9. However, the petitioner was not granted a proper opportunity to present their arguments during this assessment process. Ext.P8 concluded by advising the petitioner to file an appeal under Section 11(1) with the Second Respondent. In compliance, the petitioner filed Exts.P9 and P10 composite appeals against Ext. P7 series demand notices before the second respondent. 9. The second respondent returned Exts.P9 and P10 composite appeals stating that separate appeals were required for each individual assessment order. The second respondent further clarified that the appeals could only be considered if the first instalment of the assessed building tax was remitted. These requirements were deemed necessary for the appeals to be maintainable. By Ext. P12, the petitioners approached the first respondent under Section 3(2) of the Act requesting a determination regarding the applicability of the exemption in their case. In addition, they requested a stay on further proceedings. In response, the second respondent reiterated that the appeals could only be processed or kept pending for the decision of the government upon receipt of the required payments as mandated under the Kerala Building Tax Rules. In the meanwhile, the petitioners received Ext. P15 series of revenue recovery notices issued under Section 7 of the Kerala Revenue Recovery Act. Aggrieved by the same, the petitioners filed the present writ petition. 10. In response to the petitioner's assertions, the 3rd respondent filed a counter-affidavit. In the counter-affidavit it is stated that the Village Officer, Kothamangalam, submitted an inspection report on seven buildings (six hostels and one canteen) owned by the petitioner. Based on this report, Form IV notices were issued pursuant to Sections 9(2) / 9(4) of the Act. The petitioner neither responded to these notices nor submitted any relevant documents to support their claim for exemption from building tax. Subsequently, the Charge Officer, representing the Tahsildar, inspected the buildings and conducted an assessment. It is stated that the petitioner did not raise any objections during this process. Thereafter assessment orders and demand notices were issued. Only upon receiving these notices the petitioner approached the respondents, seeking exemption from building tax based on Ext.P1 government order. 11. The counter-affidavit filed by the 3rd respondent further alleges that the Kerala Building Tax Act does not authorize the assessing authority to reopen a completed assessment. Therefore, the petitioner was directed to seek remedy through the appellate authority. In the meantime, revenue recovery proceedings were initiated. 11. The counter-affidavit filed by the 3rd respondent further alleges that the Kerala Building Tax Act does not authorize the assessing authority to reopen a completed assessment. Therefore, the petitioner was directed to seek remedy through the appellate authority. In the meantime, revenue recovery proceedings were initiated. The petitioner association challenged the assessment before the Second Respondent. However, the appeal was dismissed due to the failure to remit the first installment of the assessed tax, as mandated by the assessment orders. Subsequently, the petitioner approached the government, which disposed of the petition by stating that the validity of assessment would depend on the outcome of Civil Appeal No. 207 of 2012 pending before the Supreme Court. In accordance with the above, the assessing authority kept pending all further proceedings against the petitioner, and necessary instructions were issued to the Village Officer. 12. The present writ petition primarily challenges the following: The assessment orders included in Exhibit P5 series. The demand notices included in Exhibit P6 series. The revenue recovery notices issued under Section 7 of the Kerala Revenue Recovery Act (Exhibit P15 series). 13. I have heard submissions from Sri. John Jacob, learned counsel appearing for the petitioner, and the learned Senior Government Pleader representing the respondents. 14. The learned counsel for the petitioner has drawn my attention to the fact that Civil Appeal No. 207 of 2012 has been decided by the Supreme Court in Government of Kerala and another v. Mother Superior, Adoration Convent [ 2021 (2) KHC 188 ],. In this judgment a reference is made to the decision taken by the full bench of this court in Unity Hospital (P) Ltd. And another v. State of Kerala and Others [ 2011 (1) KHC 125 ], to hold that student accommodation facilities provided by educational institutions qualify for exemption under the Act, if such accommodation is a necessary facility and the primary purpose of the students' stay is to pursue their studies at the institution. The petitioner further argues that a subsequent judgment clarifies the scope of Section 3(1)(b) of the Kerala Building Tax Act, 1975. This judgment limits the exemption to buildings used for core religious, charitable, or educational activities, as well as purposes directly connected with these core activities. 15. I have considered the rival contentions. 16. The petitioner further argues that a subsequent judgment clarifies the scope of Section 3(1)(b) of the Kerala Building Tax Act, 1975. This judgment limits the exemption to buildings used for core religious, charitable, or educational activities, as well as purposes directly connected with these core activities. 15. I have considered the rival contentions. 16. Section 13(1)(b) of the Kerala Building Tax Act, 1975 exempts buildings principally used for religious, charitable, or educational purposes from building tax assessments. The petitioner association contends that all the buildings assessed under Ext. P5 series of orders are used primarily for educational purposes. The assessing authority does not allege any alternative use for these buildings. Furthermore, the counter-affidavit acknowledges that the petitioner approached the government, which subsequently directed the Tahsildar to defer the assessment of the hostel buildings pending the decision of the Apex Court in Civil Appeal No. 207 of 2012. In accordance with the above direction, the assessing authority kept pending all further proceedings under the Revenue Recovery Act, and corresponding instructions were issued to the Village Officer. 17. As aforementioned, the Supreme Court issued its final judgment in Civil Appeal No. 207 of 2012 (Government of Kerala and another v. Mother Superior, Adoration Convent [ 2021 (2) KHC 188 ]) interprets Section 3(1)(b) of the Act to apply only to buildings principally used for core religious, charitable, or educational activities. In the light of this precedent and the assessing authority does not allege any alternative use for these buildings, it has the legal basis for Ext. P5 series assessment orders and xt. P6 series demand notices and is liable to be quashed. 18. In light of the foregoing discussions, this Court quash the impugned Ext. P5 series of assessment orders, Ext. P6 series of demand notices, and the consequential Ext. P15 series of proceedings initiated under the Revenue Recovery Act. The respondents are hereby directed to re-examine the claim of the petitioner association for exemption regarding the buildings assessed under Ext. P5 series of orders. The respondents shall issue appropriate orders granting exemption pursuant to Section 3(1)(b) of the Kerala Building Tax Act, 1975, in accordance with the decision in Civil Appeal No. 207 of 2012 (Government of Kerala and another v. Mother Superior, Adoration Convent [ 2021 (2) KHC 188 ]). P5 series of orders. The respondents shall issue appropriate orders granting exemption pursuant to Section 3(1)(b) of the Kerala Building Tax Act, 1975, in accordance with the decision in Civil Appeal No. 207 of 2012 (Government of Kerala and another v. Mother Superior, Adoration Convent [ 2021 (2) KHC 188 ]). This re-examination shall involve due consideration of the relevant documents and the merits of the contentions raised by the petitioner association, including the opportunity of a hearing. The writ petition is disposed of accordingly.