JUDGMENT G.C. Mathur, J. - The question which arises for consideration in this case is whether an appeal lies against an order passed under Section 213 (1) (b) of the Nagar Mahapalika Adhiniyam, substituting or mutating in the assessment list, the name of the successor for the name of the owner or occupier. It arises in the following circumstances :- 2. Raghubar Dayal and Moti Lal were entered as co-owners of certain properties in the records of the Nagar Mahapalika, Agra. Moti Lal died, and, thereupon, Raghubar Dayal applied under Section 213 of the Adhiniyam for expunction of the name of Moti Lal claiming that he was the exclusive owner of the properties. The applicants, who are the sons of Moti Lal, objected. By an order dated December 5, 1963 a sub-committee of the Mahapalika ordered the names of the applicants to be entered in place of Moti Lal in the record. Against this order Raghubar Dayal filed 'an appeal under Section 472 of the Adhiniyam. A preliminary objection was raised by the applicants that no appeal lay. But this objection was rejected by the Judge, Court of Small Causes. He, however, stayed the hearing of the appeal and directed Raghubar Dayal to file an objection under Section 473 (c) before the Mukhya Nagar Adhikari. The applicants thereupon filed an appeal before the District Judge. The Additional District Judge, who heard the appeal, held that the appeal against the order under Section 213 (1) (b) was competent and directed the Judge, Court of Small Causes, to hear the appeal on the merits. The applicants have challenged the order of the Additional District Judge in this revision. 3. Section 207 of the Adhiniyam says that the Mukhya Nagar Adhikari shall cause an assessment list of all buildings or lands or both in the city to be prepared containing (a) Name of the street or Mahalla in which the property is situated. (b) The designation of the property, either by name or by number. (c) Names of the owner and occupier (d) Annual letting value, etc., and (e) The amount of tax assessed. 4. Section 208 requires the assessment list to be published. Section 209 provides for the filing of objections to the assessment list and for the disposal of those objections. Section 210 makes provision for the authentication and custody of the list. (c) Names of the owner and occupier (d) Annual letting value, etc., and (e) The amount of tax assessed. 4. Section 208 requires the assessment list to be published. Section 209 provides for the filing of objections to the assessment list and for the disposal of those objections. Section 210 makes provision for the authentication and custody of the list. Section 211 lays down that the assessment list shall be revised every five years in accordance with the provisions of Section 207 to 210. Section 212 makes entries in the list conclusive. Section 213 provides for amendment and alteration of the assessment list in respect of the particulars contained therein. Section 213 (1) (b) is in these words :- "The executive committee or a sub-committee thereof appointed in this behalf may at any time alter or amend the assessment list (a) ................... (b) by substituting for the name of the owner or occupier of any property the name of any other person who has succeeded by transfer or otherwise to the ownership or occupation of the property; ......." The committee is required to give notice to the persons interested before making the alteration. Sub-sec. (2) of Section 213 makes the provisions of Section 209 applicable to the amendment of the list. Sub-sec. (3) of this section is important. At the relevant time it stood thus : - "Every alteration made under sub-sec. (1) shall be authenticated by the signature or signatures of the person authorised by Section 210 and, subject to the result of an appeal under Section 472, shall take effect from the date on which the next instalment falls due." Sub-sec. (3) clearly contemplates an appeal against orders of alteration or amendment in the list. 5. Section 472 (1) which provides for appeals was in these words at the relevant time : "Subject to the provisions hereinafter contained, appeals against any annual or tax fixed or charged under this Act shall be heard and determined by the Judge." and sub-sec. 2 (d) of this section provided: "2. No such appeal shall be heard unless- .............. 5. Section 472 (1) which provides for appeals was in these words at the relevant time : "Subject to the provisions hereinafter contained, appeals against any annual or tax fixed or charged under this Act shall be heard and determined by the Judge." and sub-sec. 2 (d) of this section provided: "2. No such appeal shall be heard unless- .............. (d) in the case of an appeal against any amendment made in the assessment book for property taxes during the financial year, an objection has been made by the person aggrieved within 15 days after he first received notice of such amendment, and his objection has been disposed of." Sec. 473 (c) is also relevant and provided : "For the purposes of Section 472 cause of complaint shall be deemed to have accrued as follows; namely- (c) In the case of an appeal against any amendment made in the assessment book for property taxes during the financial year, on that date when the objection made to the Mukhya Nagar Adhikari by9- the person aggrieved against such amendment is disposed of." 6. Section 472 (2) (d) and 473 (c) clearly indicate that the Legislature contemplated appeals against all orders of alterations and amendments in the assessment list made under Section 213 (1) . In addition to, this, the express words of sub-sec. (1) of Section 472 also cover a case of substitution or mutation in the assessment list of the name of the successors for that of the original owner or occupier. In such a case the successors become liable to the tax and it can be said that they are charged with the payment of tax in place of the original owner or occupier. Thus the substitution or mutation order is an order charging the successors with payment of tax and clearly falls with. in the ambit of Section 472 (1) . We are therefore of opinion that an order under Section 213 (1) (b) directing substitution or mutation of the names of the successors in place of the original owner or occupier is subject to appeal under Section 472 (1) . 7. in the ambit of Section 472 (1) . We are therefore of opinion that an order under Section 213 (1) (b) directing substitution or mutation of the names of the successors in place of the original owner or occupier is subject to appeal under Section 472 (1) . 7. In this connection our attention was drawn to the decision of Oak, J., as he then was in Zahid Husain Jafri v. Additional Commissioner, 1958 ALJ 12, wherein he has held that an appeal lies under Section 160 of the U. P. Municipalities Act from an order of mutation under Section 147 (3) of that Act. We find that the provisions of Section 160 of the Municipalities Act are wider than those under Section 472 of the Adhiniyam as that section clearly refers to Section 147 (3) while Section 472 of the Adhiniyam does not directly refer to Section 213 (1) (b) of the Adhiniyam. 1: This decision, therefore, is not very helpful in deciding the present case. But we can see no reason why, if an appeal is provided by the Legislature against the alteration or amendment of the assessment list under the Municipalities Act, the Legislature should intend not to provide for an appeal against similar orders under the Nagar Mahapalika Adhiniyam. 8. We, are, therefore, of opinion that an appeal under Section 472 of the Adhiniyam lies against an order of substitution or mutation passed under Section 213 (1) (b) . The case will now be listed before the learned Single Judge for disposal.