Judgment :- 1. The petitioner challenges Ext. P-5 notice of the Tahsildar, the 3rd respondent, dated 8-11-1979, under the Revenue Recovery Act, in respect of Rs 35,547.52 alleged to be arrears due from the petitioner under the Kerala General Sales Tax Act for the years 1958-59 and 1962-63 This amount is claimed to be what is due under the revised assessment made pursuant to the order of the Sales Tax Tribunal setting aside the original assessment and directing re-consideration of the matter. The complaint of the petitioner is that he was not given pre-assessment notice before the original assessment was revised and he had no knowledge of the revised assessment. In Ground A, the petitioner states: "no notice was given before the revision of assessments and no order was served on the assessee after the revisions. Hence the amount claimed on the basis of the revised assessment orders is not actually and legally due from the dissolved firm. That being so the revenue recovery proceedings are quite illegal." In answer to the petitioner's averment, this is what the respondents say in the counter affidavit sworn to by the Assistant Secretary (Law), Board of Revenue (Taxes), Ernakulam. Para.12 says: "12 (1) Averment in ground A is false. The petitioner has contended that no revised orders were issued and no notice was given before revision. I submit that the notice proposing the revision of assessment for 1958-59 and 1962-63 were served by affixture at the last known place of business on 19 91978. The revised orders were also served in the same manner on 13121978. x" The stand of the respondents is thus clear. Their stand is that notice was served by affixture at the last known place of business. In the reply affidavit, the petitioner has denied any knowledge of affixture. 2. R.63 of the Kerala General Sales Tax Rules, 1963, provides: "Service of summons, etc. The service on a dealer of any summons or order under the Act or these rules may be effected in any of the following ways namely. In the reply affidavit, the petitioner has denied any knowledge of affixture. 2. R.63 of the Kerala General Sales Tax Rules, 1963, provides: "Service of summons, etc. The service on a dealer of any summons or order under the Act or these rules may be effected in any of the following ways namely. (a) by giving or tendering it to such dealer or manager or agent; (b) if such dealer or his manager or agent is not found, by leaving it at his last known place of business or residence or by giving or tendering it to any adult member of his family; or (c) if the address of such dealer is known to the assessing authority by sending it to him by registered post or, (d) if none of the modes aforesaid is practicable by affixing it in some conspicuous place at his last known place of business or residence or by publication in a newspaper." (emphasis supplied) Clause (d) shows in which circumstance can service by affixture be resorted to. Only, if none of the three modes mentioned under clauses (a) to (c) is practicable can service be made by affixture. It has therefore to be shown by clear averment that attempt had been made under any one or all of the three modes. There is no whisper in the counter affidavit that either the pre-revision notice or the revised order of assessment had been given or tendered to the petitioner or his manager or agent or it had been left at the last known place or business, or residence of the petitioner or tendered to any adult member of his family. There is no averment that the address of the petitioner was not known to the respondents. If the address was known to them, it is not stated why the notice or the order had not been sent to him by registered post. In the absence of any averment to show that service by any one of the three modes under clauses (a) to (c) of R.63 was not practicable, it is not open to the respondents to say that proper and effective service had been made by a mere affixture of the notice of the order in some conspicuous place "at the last known place of business" of the petitioner. All that they say in the counter affidavit is that it was served by affixture. All that they say in the counter affidavit is that it was served by affixture. That is not sufficient In the circumstances, the conclusion is irresistible that the petitioner had hot been properly served either with the pre-revision notice or the order of revised assessment. Ext. P-5 is accordingly quashed. However, it will be open to the respondents to issue fresh notice to the petitioner and proceed with the revision of the assessment. Subject to this observation, the O. P. is allowed. No costs. Allowed.