Summary: (a) Constitution of Pakistan ----Arts. 142, 184, 270-A, Fourth Schedule (Entries 2 & 50), Eighteenth Amendment—Legislative competence—Levy and collection of tax on immovable property—Jurisdiction of Federation and Cantonment Boards—Effect of constitutional amendments. Tax on immovable property, including tax on annual rental value, has historically been a provincial subject. The legislative competence to levy, charge, or recover such tax was never vested in the Federation except during the Martial Law period through the promulgation of the *Cantonments (Urban Immovable Property Tax and Entertainment Duty) Order, 1979 (P.O. 13 of 1979)*. The Sindh High Court, tracing legislative history from the Government of India Act, 1935 to the Constitution of 1973, held that after the restoration of the Constitution in 1985 and the 18th Amendment, the subject of property tax reverted exclusively to the Provinces. Consequently, the Federation and all Cantonment Boards lacked competence to impose any such tax, the field being expressly excluded from the Federal Legislative List (Entry 50) and reserved for the Provinces under Art. 142(c). (b) Constitutional law ----Art. 270-A—Validation of laws enacted during Martial Law—Scope and limitation—Protection of Presidential Orders—Applicability of Benazir Bhutto case. Presidential Orders issued between 1977 and 1985 were granted temporary protection under Art. 270-A and the Seventh Schedule but lost their efficacy after the restoration of the Constitution and the 18th Amendment. Following the principle laid down in *Benazir Bhutto v. Federation of Pakistan* (PLD 1988 SC 416), laws protected by Art. 270-A could not override the Constitution or survive beyond the cut-off date. The Court reaffirmed that P.O. 13 of 1979, enacted when the Constitution was in abeyance, stood eclipsed and could not continue to authorize taxation in cantonment areas after constitutional restoration. (c) Cantonment Act, 1924 ----Ss. 60, 80, 106 & 109—Scope—Taxation powers of Cantonment Boards—Requirement of federal sanction and publication—Effect of August 2023 amendment. Section 60 empowers Cantonment Boards to impose only those taxes which may lawfully be imposed by a municipality in the province and only with the *previous sanction of the Federal Government* and publication in the official gazette. In the absence of an existing provincial levy, such power cannot be exercised. The 2023 amendment inserting the term “fee” into Section 60 did not expand the scope to authorize new levies; fiscal statutes must be strictly construed. Moreover, as per *Mustafa Impex v. Government of Pakistan* (PLD 2016 SC 808), prior sanction of the Federal Cabinet, not a Division, is mandatory. The amendment delegating such sanction to a Division was held inconsistent with democratic and constitutional principles. (d) Constitutional interpretation ----Entry 2, Fourth Schedule—Not a taxing entry—Entry 50 exclusive field—Distinction between taxes and fees. Entry 2 of the Fourth Schedule, often cited by Cantonment Boards, is a general administrative entry concerning federal subjects and does not include power to tax. Taxing entries are exhaustively enumerated from 43 to 53. The levy under discussion being a charge on immovable property clearly falls under Entry 50, which, post-18th Amendment, excludes immovable property from federal jurisdiction. Argument that the levy was a “fee” under Entry 54 or S.200 of the Cantonment Act was also rejected as the exhaustive list of permissible fees therein does not cover annual rental value of property, and the principle of *quid pro quo* was not satisfied. (e) Provincial legislation ----Sindh Urban Immovable Property Tax Act, 1958—Continuity and supremacy—Applicability to cantonment areas. The Sindh Urban Immovable Property Tax Act, 1958, enacted prior to the 1979 Presidential Order, remains the governing statute for property tax within the province, including cantonment areas. Following *Pakistan v. Province of Punjab* (PLD 1975 SC 37) and *Gulzar Cinema v. Cantonment Board* (PLD 1978 Kar. 500), cantonment areas located within a province are subject to provincial taxation statutes, as they do not constitute federal territory. (f) Fiscal jurisprudence ----Distinction between tax and fee—Purpose of levy—Cantonment funds—Effect of routing revenue. The fact that amounts collected were deposited into Cantonment Funds under Ss.106–109 of the Cantonment Act does not alter the nature of the levy. A tax remains a tax regardless of the fund in which it is credited. Reliance on *Workers Welfare Fund* and *GIDC* cases was misplaced, as those levies were upheld as fees due to specific quid pro quo mechanisms, which are absent here. (g) Discrimination and equality before law (Arts. 25 & 77) ----Differential taxation between municipalities and cantonments—Classification—Validity. Different rates of taxation for identical properties situated across municipal and cantonment boundaries were held discriminatory and violative of equal protection principles. A uniform regulatory framework under provincial supervision was necessary to prevent arbitrary classifications and ensure parity in valuation and assessment. (h) Disposition— Petitions allowed. It was declared that— (i) After the Eighteenth Amendment, the Federation and Cantonment Boards have no competence, power, or jurisdiction to levy, charge, impose, or recover any tax on immovable property, including tax on annual rental value. (ii) The Province of Sindh alone has legislative and fiscal authority over the subject. (iii) All amounts collected under the impugned levy since the 18th Amendment are liable to accounting and reconciliation by the provincial government. (PLD 1975 SC 37; PLD 1978 Kar. 500; PLD 1988 SC 416; PLD 2016 SC 808; 2022 Peshawar 46; 2023 SCMR — Cantonment Board case, 13.10.2023, followed).