K. S. BHATT, J. ( 1 ) PETITIONER owns property in Bangalore City. Earlier for the year 1987 a notice was issued by the City Corporation to the petitioner to pay a sum of Rs. 15,425. 25 ps. as property tax inclusive of health cess, library cess and beggary cess. The annual rental value of the property was Rs. 47,100/ -. This notice was to be effective from 1-10-1987. The petitioner complied with the notice since the petitioner had no grievance against the demand proposed in the said special notice. However, in December, 1987 second respondent issued another special notice dated 5-12-1987 purporting to be a special notice under Section 147 of the Karnataka Municipal Corporations Act, 1976 ('the Act' for short) read with Schedule 3, Part II thereof. In the said notice the second respondent proposed to revise the annual rental value of the petitioner's property from Rs. 47,100/- to Rs. 5,65,489/- and consequently the property tax was to be Rs. 1,48,158. 13 ps. with effect from 1-4-1986. The petitioner was asked to file objections, if any, to the said notice. The petitioner sought the basis for such proposal so as to enable the petitioner to file objections. Repeatedly the petitioner moved the second respondent for the basis. The petitioner pointed out that without the basis for the special notice it was impossible for the petitioner to show cause and explain that the basis was wrong. The petitioner was directed to be present before the first respondent and once again request was made on behalf of the petitioner for the basis for the proposal. The first respondent refused to furnish the basis for the proposal. The petitioner pointed out that the property tax was proposed tp be enhanced by 950% and the annual rental value was proposed to be increased over 1000% and on the face of it this proposal was erroneous and will be arbitrary in the absence of proper material for such a revision. ( 2 ) THE petitioner has approached this Court for a direction to the respondents to afford proper opportunity to the petitioner before revising the annual rental value as well as the property tax in case the same will have to be revised by the respondents. ( 2 ) THE petitioner has approached this Court for a direction to the respondents to afford proper opportunity to the petitioner before revising the annual rental value as well as the property tax in case the same will have to be revised by the respondents. The petitioner also pointed out that the principle involved is settled by a Bench decision of this Court in Khan Sahib Abdul Shakoor v Corporation of the City of bangalore, 1972 (1) Mys. L. J. 238. ( 3 ) NO statement of objection was filed to the writ petition. The respondents have not even taken this Court into confidence for the proposed action. The procedure for revising the assessment is found in Part II of Schedule 3 to the Act. Schedule 3 contains the taxation Rules. Rule 8 thereof empowers the Commissioner to amend the property tax assessment books at any time between one general revision and another, etc. , after giving notice to the parties concerned and hearing their objections, if any. Similar procedure is contemplated for the issuance of the special notice under Rule 9. As per Rule 11, the Commissioner will have to decide the question involved only after giving a reasonable opportunity to the assessee to appear either in person or by authorised agent to represent his case. Even without Rule 10, there cannot be any doubt that the party affected will have to be given a reasonable opportunity to meet the case sought to be made out against him when the basis of tax is sought to be altered in the assessment proceedings. Property of the petitioner has already been assessed for taxation at a particular rate. It is now sought to be revised by the said notice. The burden is entirely on the authorities who seek the revision to disclose the basis for the same and come to a conclusion on the basis of the relevant material. It is impossible for any assessee to make any submission to the special notice proposing enhancement of the tax, unless the basis for the proposal is disclosed to him. The burden is entirely on the authorities who seek the revision to disclose the basis for the same and come to a conclusion on the basis of the relevant material. It is impossible for any assessee to make any submission to the special notice proposing enhancement of the tax, unless the basis for the proposal is disclosed to him. The division Bench in the aforesaid decision at page 241 states:"if the respondent-Corporation wants to revise the annual value of any building it ought to give the basis for the revision of the value which it proposes to make so as to afford an opportunity to the assessee to rebut the proposed valuation. "the assessee can only rebut the alleged case that has to be made out by the respondent. ( 4 ) IN these circumstances there can be no doubt that the petitioner is entitled to seek the disclosure of the basis for the proposed action. The respondents have acted quite arbitrarily in ignoring the request of the petitioner. Since a heavy tax is proposed against the petitioner and on the face of it the proceedings disclose that it suffers from a material illegality, I deem it fit to interfere with the proposal at this stage in the exercise of my writ jurisdiction. For the reasons stated above the petitioner is entitled to succeed. Respondents are directed to disclose the proposed revision of assessment, i. e. , the basis for the proposed enhancement of the annual value as well as the enhancement of the property tax before taking any decision in pursuance of the special notice issued already, in case they propose to proceed with the matter further. Respondents are directed accordingly. ( 5 ) IN the result, the proceedings commenced with the special notice Annexures-A and A-1 are set aside with liberty to the respondent to proceed afresh in accordance with law subject to observations made above. Rule is made absolute. --- *** --- .