Corporation either by the petitioner or by the 1st respondent. The 2nd respondent Corporation, therefore, raised a demand on the 1st respondent in the year 2011 and in turn the 1st respondent, placing reliance on the agreement entered into with the petitioner issued a demand in a like sum to the petitioner towards liability for property tax. It is apparent that both the demands, inasmuch as they pertain to a period more than three years prior to the date of the recovery notice, are barred by limitation. Although, it is vehemently contended by learned counsel for the 1st respondent that, the fact of non-payment by the petitioner of property tax to the 2nd respondent Corporation, came to its notice only when it received a notice from the 2nd respondent Corporation in the year 2011, the fact remains that, if the 1st respondent is relying on the terms of the agreement entered into with the petitioner for justifying the demand, then they ought to have raised the demand within a period of three years from the date of breach by the petitioner of the terms of the agreement. When viewed in that context, it is apparent that the breach committed by the petitioner was in the payment of property tax, which is a yearly levy. The breach would have to be attributed to the year in respect of which the petitioner defaulted in the property tax dues. In that view of
