ISSUE:
Whether the publication of tax proposals and draft rules under Section 131(3) of the U.P. Municipalities Act mandatory or directory and was the process validly followed in this case?
Whether Section 135(3) conclusively validates the imposition of a tax despite procedural defects under Sections 131 and 94(3)?
RULE:
Mandatory vs. Directory Compliance: Provisions requiring public objections for taxation (Section 131(3), first part) are mandatory as they ensure taxpayer participation, while the manner of publication (Section 94(3)) is directory, requiring substantial rather than strict compliance.
Conclusive Proof Doctrine: Section 135(3) establishes that a notification in the Government Gazette serves as conclusive proof that the tax has been imposed in accordance with the Act, provided there is at least substantial compliance with the mandatory procedural requirements.