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, Local Government Department. The dispute concerned whether the Ammonia Gas Storage Tank of M/s National Fertilizers Limited at Naya Nangal could be subjected to house tax under the Punjab Municipal Act, 1911, with the Company arguing that the tank was an integral part of its plant and machinery and not a 'building' liable to such tax. The appellate authority had held that retrospective assessment for the years 1982-83 to 1989-90 was impermissible, but upheld the assessment for 1991-92 to 1994-95, and directed that amounts already deposited be adjusted against future tax dues rather than refunded. The Company challenged the validity of the entire assessment, contending that the capital cost of the whole installation (including refrigeration machinery, compressors and pressure-control systems) could not be adopted as the value of a 'building' for tax purposes, relying on Supreme Court precedents holding that Entry 49 of List II of the Seventh Schedule to the Constitution permits taxation of lands and buildings only, not plant and machinery. The judgment text provided ends before the court's final ruling is stated.