Two writ petitions were filed before the Punjab and Haryana High Court challenging an order dated 30.05.1995 passed by the Secretary to the Government of Punjab, Department of Local Government. The dispute concerned whether the Ammonia Gas Storage Tank of M/s National Fertilizers Limited at Naya Nangal could be subjected to house tax by the Municipal Council, Nangal, under the Punjab Municipal Act, 1911. The Municipal Council had assessed house tax on the tank by treating its entire capital cost of ₹1,51,88,006/- as the basis for determining annual rental value, while the Company contended that the tank was an integral part of its plant and machinery and not a 'building' liable to house tax. The appellate authority had held that retrospective assessment for 1982-83 to 1989-90 was impermissible but upheld the assessment for 1991-92 to 1994-95, directing that amounts already deposited be adjusted against future tax liability rather than refunded. Both parties challenged this order, with the Company arguing that the tank was not a building under Entry 49 of List II of the Seventh Schedule to the Constitution and that plant and machinery costs could not be included in the assessment.