JUDGMENT - V.S. DESHPANDE, J.:---These four appeals by the same concern, raise a common question of law and can conveniently be disposed of by this common judgment. The appellants are the owners of the two houses, viz., Shahibaug House and Ahmedabad House at Ballard Estate, Fort, Bombay. Both the Houses are liable to property tax under the Bombay Municipal Corporation Act of 1888, hereinafter referred to as the Act. The rateable value of the first property for the year ending on 31st March, 1970, was fixed at Rs. 27,190/-, while that of the second at Rs. 24,965/-. It was proposed to be raised to Rs. 3,19,920/- and Rs. 1,44,905/- respectively for the year ending on 31st March, 1971, by special notices dated 23rd March, 1971 under section 162(2) of the Act. These notices were served on the appellant on 26th March, 1971. Section 163 of the Act enables the owner to file a complaint against any such proposed increase and the Corporation has to hear and determine the same in the light of the objections. Such a complaint, however, has to be filed within 15 days of service of the notice or any shorter period indicated in the notice itself. Rather than file such a complaint within the period so prescribed, the appellant asked for extension of time for filing such a complaint by a letter dated 10th April, 1971, sent just on the 15th day of receipt of the special notice on 26th March, 1971. The appellant, however, filed the complaint on 14th April, 1971 after the expiry of 15 days, finding no response from the Corporation to their request for extension of time. 2. The Act does not contemplate preferring or entertaining such complaints after the expiry of the period prescribed under section 163 read with section 162(2) of the Act, nor does it authorise the Corporation or the concerned officer to condone any delay therein. Section 162 requires the Corporation to issue special notice for the benefit of the assessee-owner directly affected by such increase, in addition to a general notice of proposed increased in rateable values of the properties in the process of revision thereof. The underlying intent appears to be to enable the affected owners to have their say against the proposed increase if given within the time prescribed. The underlying intent appears to be to enable the affected owners to have their say against the proposed increase if given within the time prescribed. The Corporation appears to have refused to take notice of the complaint, as it was not competent to entertain complaints after the expiry of 15 days from the service of the notice. 3. In due course, the rateable values were finalised and tax was assessed on the basis thereof. A bill was served on the appellants in respect of two years, i.e. 1970-71 and 1971-72, for each one of these two properties. The appellant thereafter filed these four appeals under section 217 of the Act challenging the rateable value so increased. They also deposited the tax demanded under the bill, in compliance with the condition for hearing of such appeal, indicated in section 218(2)(d) of the Act. 4. The Additional Chief Judge, Small Causes Court, dismissed these four appeals on the ground that no appeal against increased rateable value is competent, when no complaint was filed against the proposal to increase the same, in time under section 163 of the Act. It is the validity of this order that is challenged in these four appeal. 5. Mr. K.K. Vyas, the learned Advocate appearing for the appellant contends that the conclusion of the appeal Court is not borne out by the wording of section 217 of the Act. He contends that section 217(1) of the Act confers right of appeal against the fixation of rateable value on receipt of "a bill of Tax" independently of his right of complaint and decision thereof under section 163 of the Act. Such a right, so contends the learned Advocate, is available even to the owner who could not avail of the remedy of complaint under section 163 within time. The condition in Clause (b) controls the right of appeal challenging the rateable value before the presentation of a bill for tax. Appeal challenging the rateable value after the receipt of the bill is governed by Clause (d) and not by Clause (b). Mr. Walawalkar, the learned Advocate for the respondent Corporation on the other hand, supports the reasoning of the appeal Court and contends that filing of a complaint is a "must" under the scheme or section 217(2) for availing of any right of appeal against the fixation of any rateable value. Mr. Walawalkar, the learned Advocate for the respondent Corporation on the other hand, supports the reasoning of the appeal Court and contends that filing of a complaint is a "must" under the scheme or section 217(2) for availing of any right of appeal against the fixation of any rateable value. The acquiescence in the proposal to raise the value indicated in the special notice under section 162(2) is equivalent to an admission of there being no error therein to require any interference in appeal. 6. Section 217 of the Act is quoted by the learned Appellate Judge. It is unnecessary to quote in extenso. It does not expressly confer any right of appeal. It provides for the forum for hearing the appeals against (1) rateable value fixed or (2) tax charged. Our attention is not drawn to any other section expressly conferring any such right of appeal. We do not, however, find any difficulty in spelling out such right of appeal from the very provision of naming the forum for its disposal. The legislature could not have thought of providing for the forum for hearing and disposal of the appeals, unless it had intended also to confer such right of appeal on the aggrieved owner. Provisions for mere forum would become redundant if no right of appeal is inferred therefrom. The right of appeal thus is implied in sub-section (1) of section 217 itself. The assessee is entitled to prefer an appeal against fixation of the rateable value or against charging of the tax amount. 7. Sub-section (2) of section 217, however, makes the hearing of such appeals dependent on compliance with certain conditions. Thus, Clause (a) prevents the hearing of the appeal unless it is brought within the limitation prescribed i.e. 15 days from the accrual of the cause of complaint. Clause (b) prevents the hearing of an appeal against the rateable value unless complaint is first made under section 163 and the same has been disposed of. Clause (c) also prevents the hearing of the appeal against amendment in the assessment book under section 167 unless a complaint against the same is made first within time and is disposed of. Clause (d) of section 217(2) then reads as follows : 2. Clause (c) also prevents the hearing of the appeal against amendment in the assessment book under section 167 unless a complaint against the same is made first within time and is disposed of. Clause (d) of section 217(2) then reads as follows : 2. But no such appeal shall be heard by the said Chief Judge unless : (d)" In the case of an appeal against a tax, or in the case of an appeal made against a rateable value after a bill for any property tax assessed upon such value has been served on the appellant, the amount claimed from the appellant has been deposited by him with the Commissioner." 8. These four conditions are different and independent of each other, excepting the condition as to limitation under Clause (a) which is common. The three other conditions deal with appeals under three different situations. Section 140 of the Act authorises levying of the different species of property taxes at certain percentages of the rateable value of the properties which in turn furnishes a basis of tax computation. The concept of rateable value is indicated in section 154 of the Act, while the procedure for its fixation is prescribed under sections 155 to 168 of the Act. Entries as to the same are made in due course in the assessment book maintained for this purpose and the same become conclusive when certified under section 166 of the Act subject to decision in appeal. The tax is calculated on the basis thereof and charged. 9. As soon earlier, section 217(1) contemplates appeals against (1) rateable value fixed and also against (2) the taxes charged thereon. The question whether, in the appeal against tax charged, correctness of rateable value can also be challenged need not be gone into in this case. Clauses (b) and (d) on the face of them deal with right of appeal against the fixation of rateable value at two different stages. Clause (b) deals with the stage when complaint is filed under section 163 and is disposed of to the detriment of the owner. As seen earlier, section 163 permits complaint to be filed within the period prescribed in the special notice which cannot exceed 15 days as indicated by section 162(2). Clause (b) deals with the stage when complaint is filed under section 163 and is disposed of to the detriment of the owner. As seen earlier, section 163 permits complaint to be filed within the period prescribed in the special notice which cannot exceed 15 days as indicated by section 162(2). Right of complaint is lost if not availed of within the period fixed in the notice and as section does not authorise entertaining of complaint after the expiry of such period. But that does not make the valuation final or unchallengeable. There is no indication of such finality in section 163 or in sub-section (1) of section 217, which confers the right of appeal. 10. Clause (d), on the other hand expressly contemplates the existence of such right of appeal even after a bill for any tax is served on the owner. The Act or the Rules do not prescribe any limitation requiring the bill to be presented within any particular period of finalisation of assessment book under section 166 of the Act. The bill can conveniently he served long after the period of 15 days or 15 months of such finalisation of the assessment book. This right of appeal is not made conditional under section 217(1) or section 217(2)(d) on making of this complaint under section 163. In other words, this right is available to the owners who have not availed of the remedy of complaint under section 163. The owner, however, has to deposit the tax if he wants to avail of the right of appeal at this late stage without availing the right of complaint under section 163 of the Act. The cause of complaint, within the meaning of Clause (a) of sub-section (2) of section 217 for limitation for appeal against fixation of rateable value in the case under Clause (b) is also different from the one for appeal under Clause (d). Disposal of the complaint to his detriment is the cause of complaint in the one while service of the tax bill is the cause of appeal in the other. The condition precedent of filing the complaint and its disposal contemplated under Clause (b) thus cannot be applicable to the appeal permissible under Clause (d) of section 217(2) of the Act. Mr. Walawalkars contention to that effect appears to us to be untenable. 11. Mr. The condition precedent of filing the complaint and its disposal contemplated under Clause (b) thus cannot be applicable to the appeal permissible under Clause (d) of section 217(2) of the Act. Mr. Walawalkars contention to that effect appears to us to be untenable. 11. Mr. Walawalkar then contends that the legislature could not have thought of conferring right of appeal at two different stages against the same rateable value. The contention apparently appears to be plausible. It cannot, however, stand scrutiny. It is not a question of conferring two rights of appeal against the same order. It is merely a question of giving remedies to challenge the rateable value. Obviously, the owner cannot claim any right of appeal afresh under Clause (d) if he had filed a complaint and also an appeal against the order disposing of such a complaint. Aggrieved owners may not find it possible to file the complaint within the time prescribed for variety, of good reasons even if their grievances happen to be well founded. Absence of any provisions for condoning delay in suitable cases itself is suggestive of legislative intent to furnish another opportunity to challenge its correctness. That it should not have been made final or unchallengeable under the terms of section 163 is another indication of the same intention. It is pertinent to note that sub-section (2) of section 166 makes entries in the assessment book conclusive subject to "next following section", i.e. section 217 to section 219 dealing with appeals and modification thereof in consequence thereto. 12. The impugned orders of the Additional Chief Judge in all the four appeals are thus liable to be quashed. We accordingly set aside the said orders and remand the matter to the learned Chief Judge for disposal of the appeals of the appellant on merits. 13. There will be no order as to costs in the circumstances of the case. Orders set aside and matter remanded back. -----