Properly tax-Exemption-"Used for the purpose of a factory" and "Rent"-Meaning of-Punjab Urban Immovable Property Tax Act, 1940 (Pb. 17 of 1940), ss. 3, 4 -Punjab Urban lmmovable Property Tax Rules, 1941, r. 18

The property involved in the first appeal was a set or rooms used for indoor games b)' the mill employees, one big - hall used as the Gurkha Guards Club, a set of rooms used as Officers' Club and a set of rooms used as residential quarters by workers of the mills. The property involved in the second appeal consisted of 200 quarters which had been allotted to the workers of the factory for their occupation. The question was whether these properties were exempted from taxation under s. 4 of the Punjab Urban Immovable Property Tax Act, 1940, or not, The assessing Authority held that these properties were !fable to taxation, Appeals against the orders of the Authority were rejected by the Deputy Excise and Taxation Commissioner. The respondents moved the High Court under Art. 226 of the Constitution for getting the orders quashed. The High Court held in both cases that the petitioners were entitled to exemption prayed for and quashed the orders of assessment. The State of Punjab came to this Court against the order of the High Court.