JUDGMENT Basudeva Panigrahi, J.: Since in both these Writ Petitions there being common question of facts and law, therefore, they were heard together and have been disposed of hereunder. 2. The petitioners in W.P. No. 2043 of 1996 are the Trustees of Estate Babulal Agarwala Trust. The Trust is the owner of the premises No. 133, Acharya Jagadish Chandra Road, Calcutta (hereinafter referred to as 'the said property'). The premises has been comprised of land with four-storied building fully occupied by the tenants. The annual valuation of the property was fixed at Rs.45,269/- before the 1st quarter of 1985-86. By a purported notice dated 15th December, 1988 under section 184(3) of the Calcutta Municipal Corporation Act, 1980, the Calcutta Municipal Authorities informed the petitioner that annual valuation of the said building was assessed at Rs.3,09,960/- with effect from 1st quarter of 1985-86. Petitioners have stated to have filed an objection against such valuation by a letter dated 27th December, 1988. The Municipal Authorities again sent another notice on 1st December, 1993 by enhancing annual valuation with effect from 2nd quarter 1991-1992 at Rs.3,71,950/-. The petitioners who are the trustees of the Estate Babulal Agarwala, have raised objection on 15th December, 1993. The C.M.C. Authorities informed the petitioners by a notice dated 31st May, 1996 that the annual valuation of the property had been determined at Rs.3,71,950/- with effect from 1st quarter 1991-92 and thereby invited objection from the petitioners against such determination. 3. It has appeared that on 13th June, 1996, then the petitioners' representative Sri Kanai Lal Roy went to the office of the Hearing Officer VII, he found to his utter dismay that the said case was not fixed for hearing on that day, subsequently, the petitioners received a letter vide Memo No. 11722 dated 12th June, 1996, whereby the petitioners were informed that the annual valuation of the property was determined by Hearing Officer on 12th June, 1996 at Rs.3,71,950/- from 1st quarter 1985-86. They were informed that the valuation was fixed at Rs.3,71,950/- on 12th June, 1996 with effect from 2nd quarter 1991-92. Petitioners have therefore, challenged the annual valuation, determined as arbitrary, unlawful and illegal inasmuch as while the date was fixed fur hearing on 13-6-1996, how could the Hearing Officer fix the annul valuation on 12th June, 1996. The annual valuation before 1st quarter 1985-86 was determined at Rs. Petitioners have therefore, challenged the annual valuation, determined as arbitrary, unlawful and illegal inasmuch as while the date was fixed fur hearing on 13-6-1996, how could the Hearing Officer fix the annul valuation on 12th June, 1996. The annual valuation before 1st quarter 1985-86 was determined at Rs. 45,269/- then, how such valuation could be astronomically raised at such disproportionate rate. Although the written objection was filed before the Hearing Officer by the Trustees, such written objection were not at all taken into consideration. The annual valuation was fixed without any application of mind and/or in a closed mind by the Assessing Officer. 4. Petitioner Ashoka Hotel has claimed to be one of the tenants in the Estate Babulal Agarwala and has been paying monthly rental at Rs. 5,700/-. It has been, inter aila, stated by the petitioners that the Calcutta Municipal Corporation has not served any notice upon Ashoka Hotel. The annual valuation assessed by the Assessing Officer is unreasonable, unconscienable, illegal and whimsical. The C.M.C. authorities similarly served two notices proposing to raise annual valuation for different periods and then C.M.C. raised annual valuation at a very inflated and high figure by increasing annual valuation in manifold. Although the date was fixed on 13-6-1996, but the order was communicated before the actual hearing take place i.e. on 12-6-1996. No reason has been assigned by the C.M.C. Authorities as to why they arrived at such figure. Therefore, the order is liable quashed as it was mala fide, arbitrary and unreasonable. 5. Mr. Das Adhikary, the learned advocate appearing for the C.M.C. Authorities has strongly contended that notice required to be served upon the owner was in fact served under section 184(3) and (4) of the Calcutta Municipal Corporation Act, 1980 but the order which was communicated dated 13th June, 1996, it was inadvertently stated as on 12-6-1996. The said notice was received on 7.9.1996. Although there are eight tenants as evident from the writ petitions of the Trustees but how the petitioner Ashoka Hotel has filed this case, leaving other tenants, challenging the entire valuation. There was a request by the Ashoka Hotel before the Tribunal that notice should be sent in their addresses accordingly and it has sent to them. The case was adjourned from time to time but there was no enquiry. There was a request by the Ashoka Hotel before the Tribunal that notice should be sent in their addresses accordingly and it has sent to them. The case was adjourned from time to time but there was no enquiry. In the writ petition there has been no averment that the date was fixed on 13.6.96 but actually the case was finalised on 12.6.1996. Although there has been a remedy of filing an appeal, the writ petitioner without exhausting that remedy could not have filed this writ. With these ground C.M.C. Authorities have challenged to dismiss the case. 6. The matter was heard at length earlier, but, however, this Court dismissed the writ petition filed by the petitioner Ashoka Hotel, only on a technical ground regarding maintainability of the writ petition when an alternative and efficacious remedy was available to it. The matter was, therefore, challenged in an appeal being G.A. No. 3528 of 1996, APOT/607/96 where a Division Bench of this Court has however, set aside the order of the learned Single Judge and remitted the case again to this Court for hearing on merits. That is why, the matter was heard at length again. 7. The main ground of attack by the writ petitioner is that the notice served by the C.M.C. Authorities simultaneously, for different periods is improper and illegal for such periodic revision of valuation. Notice should be sent at every stage. Notices subsequently issued/served for the earlier period of proposed revision sought to be made will be meaningless. 8. Under section 179 of the Calcutta Municipal Corporation Act, 1980, it has provided ample and unfettered powers to the Corporation to make periodic assessment. In order to appreciate respective contentions of both parties I quote here below the provision of sections 174, 179, 180 and 184. "174. Determination of annual valuation.- (1) Notwithstanding anything contained in the West Bengal Premises Tenancy Act, 1956 (West Ben. In order to appreciate respective contentions of both parties I quote here below the provision of sections 174, 179, 180 and 184. "174. Determination of annual valuation.- (1) Notwithstanding anything contained in the West Bengal Premises Tenancy Act, 1956 (West Ben. Act XII of 1956) or in any other law for the time being in force, for the purpose of assessments to the consolidated rate, the annual value of any land or building shall be deemed to be the gross annual rent including service charges, if any, at which such land or building might at the time of assessment be reasonably expected to let from year to year, less an allowance of ten per cent, for the cost of repairs and other expenses necessary to maintain such land or building in a state to command such gross rent: Provided that while determining the annual value in the case of any land or building or portion thereof exclusively used by the owner for his residential purpose, the gross annual rent of such land or building or portion, as the case may be, shall be reduced- (a) where the gross annual rent does not exceed six hundred rupees, by thirty per cent. (b) where the gross annual rent exceeds six hundred rupees but does not exceed eighteen thousand rupees, by such percentage of the gross annual rent as is worked out by dividing the gross annual rent by six hundred and substracting the quotient from thirty one, the difference being rounded off to the nearest place of decimal; Provided further that no such reduction in gross annual rent shall be made - (a) in case the total covered area in any land or building under occupation for residential purpose by the owner exceeds one hundred and fifty square meters, or (b) where a person owns or occupies for residential purpose more than one plot of land or building or portion thereof within the municipal limit of Calcutta. (2) The annual value of any land which is not build upon shall be fixed at seven per cent or the estimated market value of the land. (2) The annual value of any land which is not build upon shall be fixed at seven per cent or the estimated market value of the land. (3) If the gross annual rent of any class or classes of lands or buildings used exclusively for hospital or educational purposes or for the purposes of sports or as a place of worship or as a place for disposal of the dead cannot be easily estimated, the gross annual rent of such building shall be deemed to be five per cent of the value of the building obtained by adding the estimated cost of erecting the building at the time of assessment less a reasonable amount to be deducted on account of depreciation, if any, to the estimated present market value of the land valued with the building as part of the same premises. (4) In the case of any land or building or part thereof used for public cinema shows or theatrical performances or as a place of similar public recreation, amusement or entertainment, the gross annual rent of such land or building or part thereof, as the case may be, shall be deemed to be seven and a half per cent of the gross annual receipts in respect of such cinema shows or theatrical performances or place of public recreation, amusement or entertainment, including receipts from rent and advertisements and sale of admission tickets but excluding taxes on the sale of such tickets; Provided that the provisions of this sub-section shall not apply in the case of temporary fairs, circuses and casual shows or performances. (4A) If the gross annual rent of any land or building or part thereof cannot be easily estimated, the gross annual rent of such land or building for the purposes of sub-section (1) shall be deemed to be seven and half per cent of the value of the building obtained by adding the estimated present cost of erecting the building at the time of assessment less a reasonable amount to be deducted on account of depreciation, if any, to the' estimated present market value of the land: Provided that the estimated present cost shall not include the cost of any plant or machinery, excepting those enumerated in Schedule VIII, on the land or the building as aforesaid. (5) The annual value .as determined under this Chapter shall be rounded off to the nearest ten rupees." "179. Periodic assessment.- (1) The annual value of any land or building situated in any ward of the Corporation, which has been determined before and is in force on the date of commencement of this Act, shall remain in force, and shall be deemed to be the annual value for the purpose of assessment of consolidated rate on such land or building under this Act, until a fresh annual valuation is enforced under this Act. Provided that the annual value of any such land or building, which has been made before but not finally determined on the date of commencement of this Act, shall be determined under the provisions of the Calcutta Municipal Act, 1951 (West Ben. Act XXXIII of 1951) and shall be deemed to be the annual value in force on the date of commencement of this Act. (2) The annual valuation under this Chapter- (a) shall be made by the Municipal Commissioner or, if the State Government so directs, by the Central Valuation Board established under the West Bengal Central Valuation Board Act, 1978 (West Ben. Act VII of 1978), (b) shall have effect from the beginning of the quarter of a year ending on the 30th June or 30th September or 31st December or 31st March, as the case may be, following that in which a notice under sub-section (2) of section 184 is issued, (c) shall, subject to the other provisions of this Chapter, remain in force, in respect of each ward of the Corporation for a period of six years, irrespective of any alteration during such period in the number or boundaries of such ward, and (d) may be revised on the expiration of each such period: Provided that when annual valuation of any land or building has not been revised on the expiry of any such period for reasons to be recorded in writing, the previous annual valuation shall continue to remain in force until it is so revised: Provided further that the Municipal Commissioner may, on the expiry of such period, revise the annual valuation of such land or building at any time and such revised valuation shall take effect from the beginning of the quarter from which the annual valuation would have been revised under this clause." "180. Revision of assessment. Revision of assessment. - (1) Notwithstanding anything contained in section 179, the Corporation may by resolution direct a general revaluation of lands and buildings in any ward of the Corporation or part thereof during the currency of any period specified under this Chapter, (such general valuation shall have effect from the beginning of the quarter following that in which a notice under sub-section (2) of section 184 issued and shall remain in force in respect of each ward or portion thereof, as the case may be, for the unexpired portion of the period during which but for such revaluation the annual valuation would have remained in force.) (2) The Municipal Commissioner may cause any revision to be made in the annual valuation of any land or building in the following cases:- (i) when its ownership changes; or (ii) when any tenancy or any rent changes; or (iii) when the nature of its use changes; or (iv) when a new building is erected or an existing building is redeveloped or substantially altered or improved during the period the annual valuation remains in force; or (v) when, on an application made in writing by the owner or the person liable to pay its consolidated rate, it is established that during the period of the annual valuation remaining in force its value has been reduced by reason of any substantial demolition or has suffered depreciation from any accident or any calamity proved to the satisfaction of the Municipal Commissioner to have been beyond the control of such owner or such person; or (vi) when any land or building or portion thereof is acquired by purchase or otherwise by the State Government or the Corporation or any statutory body mentioned in clause (a) of sub-section (8) of section 171 during the period of the annual valuation remaining in force; or (vii) when any land or building, or portion thereof, is sold or otherwise transferred by the State Government or the Corporation or any statutory body mentioned in clause (a) of sub-section (8) of section 171: Provided that all land used for roads and other public purposes shall be excluded from such revaluation; or (viii) when, upon the acquisition or transfer or any land or building in part, a residual portion remains; or (ix) when it becomes necessary so to do for any other reason to the recorded in writing. (3) Any revision in the annual valuation of any land or building or portion thereof under this section shall come into force from the beginning of the quarter of a year ending on the 30th June, or 30th September or 31st December or 31st March, as the case may be, following that in which such revision becomes applicable and shall remain in force for the unexpired portion of the period during which but for such revision such annual valuation would have remained in force. (4) Notwithstanding anything contained in sub-section (1) or subsection (2) or sub-section (3), any land or building - (i) which for any reason has no annual value assigned to it under this Act, may be valued by the Municipal Commissioner at any time during the currency of the period specified in respect of such land or building under section 179 or sub-section (3) of section 180; or (ii) the valuation of which has been cancelled on the ground of irregularity, may be valued by the Municipal Commissioner at any time after such cancellation, and such valuation shall remain in force until a fresh valuation or revision is made and shall take effect from the beginning of the quarter from which the previous valuation which has been cancelled would have taken effect: Provided that the valuation made under clause (i) or clause (ii) shall remain in force for the unexpired portion of the period specified under this Chapter." "184. Public notice and inspection of assessment list.- (1) When the annual valuation under sub-section (2) of section 179 or a general revaluation under sub-section (1) of section 180 in any ward of the Corporation or part thereof, as the case may be, has been completed, the Municipal Commissioner shall cause the respective valuation to be entered in an assessment list in such form and containing such particulars with respect to each land or building as may be prescribed. (2) When the assessment list has been prepared the Municipal Commissioner shall give public notice thereof and of the place where the list or a copy thereof may be inspected, 'and every person claiming to be the owner, lessee, sub-lessee or occupier of any land or building include in the list and any authorised agent of such person shall be at a liberty to inspect the list and to take extracts therefrom free of charge. (3) The Municipal Commissioner shall give public notice of the price, time and date, not less than one month after the preparation of the assessment list as aforesaid, when he will proceed to consider the annual valuation of lands and buildings entered in the assessment list, and in all cases in which any land or building is for the first time assessed, or the annual value of any land or building is increased, he shall also give written notice thereof to the owner or to any lessee, sub-lessee or occupier of such land or building and shall also specify in the notice the place, time and date not less than one month thereafter, when he will proceed to consider such valuation. (4) When a revision in the annual valuation of any land or building has been made under sub-section (2) of section 180, the Municipal Commissioner shall cause the respective valuation to be entered in the assessment list and shall give a written notice thereof to the owner or to any lessee, sub-lessee or occupier of such land or building, and shall also specify in the notice the place, time and date, not less than one month thereafter, when he will proceed to consider such valuation. Explanation.- A written notice under this section shall be deemed to be duly served if it is sent by post under certificate of posting to the owner or to any lessee, sub-lessee or occupier of any land or building and, in such case, the date of the certificate of posting shall be deemed to be the date of service of the notice to the owner or to the lessee, sub-lessee or occupier of such land or building." 9. On a careful reading of the provision of sections 184(3) and (4), it is found that the notice regarding the decision for revision of tax can be communicated either to the owner or lessee. In this case it was received on 6-8-1996. In its endorsement it is written that 'no objection' was filed either by the assessee or by his authorised agent/representative. The above order has been passed by the Deputy Municipal Commissioner relating to assessment of annual valuation considering the papers and the documents available before him. The writ petitioner Ashoka Hotel has received those orders on 6-8-1996. In its endorsement it is written that 'no objection' was filed either by the assessee or by his authorised agent/representative. The above order has been passed by the Deputy Municipal Commissioner relating to assessment of annual valuation considering the papers and the documents available before him. The writ petitioner Ashoka Hotel has received those orders on 6-8-1996. The notice regarding annual valuation was also communicated at the premises No. 133, Acharya Jagadish Chandra Bose Road, to Ashoka Hotel informing it about the matter of Revision of Annual Valuation from time to time. The petitioner wanted to make capital about the wrong mentioning of the date of hearing noted in the Annexure 'E' as on 12-6-1996 although the case was posted on 13-6-1996. According to the date mentioned in Annexure 'A' in the writ petition filed by Ashoka Hotel, it was apparently a mistake, it ought to have been' 13-6-1996'. Although the writ petitioner Ashoka Hotel has received notice on 6-8-1996, yet it has not brought to the notice of the Corporation that the matter was disposed of ex parte without giving them a chance of hearing till this case was filed. Both the notices regarding annual valuation was for the 1st quarter 1985-86 and second quarter 1991-92. So far as the 2nd writ petition is concerned, filed by the Estate Babulal Agarwala, it has, however, stated that all notices were served upon them. Notwithstanding the service of notice, no objection was filed nor they took any step in that regard, the Hearing Officer had, therefore, passed the final order relating to annual valuation on 13-6-1996, but, in the notice that the Corporation had mistakingly written as 12-6-1996, in stead of 13-6-1996. 10. As a matter of fact it was fixed on 13-6-1996, but it was mistakingly communicated by noting the wrong date. The question of violation of principle of natural justice does not and shall not arise in this case. In the second writ petition, it has been stated that the Estate Babulal Agarwala has raised an objection by stating that the matter was fixed on 13-6-1996 and on that date their authorised agent had gone to the office who was informed that there was no date fixed for hearing but subsequently they came to know that such hearing was already concluded since 12-6-1996. The respondent Corporation has denied to have received any such objection. The respondent Corporation has denied to have received any such objection. After the closure of the valuation matter nothing could have been made by the Corporation to re-open the case. In this regard a judgment passed by a learned Single Bench of this Court in the case of Bengal Properties Put. Ltd. & Ors. vs. The Calcutta Municipal Corporation & Ors. has been reported in 1998(2) CLJ 87 can be relied upon which has been held as follows: "According to section 190 of the Act, every valuation in the assessment list prepared under section 184 shall, subject to the provisions of section 185 or the order under section 188 or section 189 be final. According to section 191 of the Act, valuation as determined under section 190 shall be entered in the Municipal Assessment Book. By virtue of the power conferred under section 192, the Commissioner after giving a notice upon the owner, lessee, sub-lessee or the occupier can amend the Municipal Assessment Book at any time in the circumstances mentioned in sub-section (1) of section 192. Therefore, the scheme of the Act, as mentioned above, indicates that there is no scope of reopening any valuation made under section 184 or 185 or any order passed under section 188 or section 189 at the instance of an owner, occupier, lessee or sub-lessee by applying under section 192 of the Act." 11. Whether the objection was filed or not amounts to a disputed question of fact, particularly, when the respondents Corporation had not admitted as regards the receipt of such objection allegedly submitted by Estate Babulal Agarwala. Therefore, while deciding a matter under Article 226 of the Constitution, the Court should as far as possible observe restraint in determining such controversial question of fact. The next question shall arise whether they can issue simultaneous notice for periodical revision of valuation. I find from the different document that the assessment proceedings were disposed of in 1996. Notices were served upon both the respondents. In this regard the C.M.C. authorities have relied upon a judgment reported in AIR 1997 Ker 350 in the case of Vigilance Council, Thiruvalla and Ors. vs. Thiruvalla Municipality where it has been held as follows: "It has been well laid down principle that in the matter of taxation laws the Court permits greater latitude to the discretion of the legislature. vs. Thiruvalla Municipality where it has been held as follows: "It has been well laid down principle that in the matter of taxation laws the Court permits greater latitude to the discretion of the legislature. The freedom of legislature as conceded not only in the choice of the article to be taxed but also as regards the manner and rate of taxation e.g., to prescribe different rates for different categories of persons or objects. (vide Khyerbari Tea Co. vs. State of Assam, AIR 1964 SC 925 ). The Courts are to be slow to interfere with the legislative direction in the matter of choice of a date for determining the basis of or commencement of liability for a tax. (vide AIR 1986 SC 662 ). The Supreme Court in D.G. Gause and Co. vs. State of Kerala, AIR 1980 SC 271 held that there is adequate procedure or machinery in the three Acts e.g., The Kerala Municipalities Act, 1960 and The Kerala Panchayat Act, 1960 for the satisfactory and proper determination of the annual value of buildings. Learned Counsel for the petitioners is right in contending that the property tax shall be assessed and the tax determined once in every 5 years. Assessment of the property tax is done in accordance with section 234. But what Municipality has attempted is not the assessment of the property tax but the fixation of rate of tax. As per the proviso 2 of sub-section (3) of section 233 a Municipality is entitled to fix the rate of tax upto 25%. Thus, there is a specific provision entitling the Municipality to levy the tax at such percentage of the annual value of the building. The annual value of the building is determined once in 5 years according to section 234 read with section 238. 'The rate of tax or the percentage of tax based on the annual value is done under section 233. There is no bar for the Municipality to revise the percentage of the annual value for the purpose of assessment. In so far as the financial rights of the local bodies are concerned unless there is specific provision against imposition this Court is not justified in interfering with the fixation of the rate of tax when the Act provides of the outer limit up to 25%. It is for the municipality to determine the percentage within the 25%'." 12. In so far as the financial rights of the local bodies are concerned unless there is specific provision against imposition this Court is not justified in interfering with the fixation of the rate of tax when the Act provides of the outer limit up to 25%. It is for the municipality to determine the percentage within the 25%'." 12. On a careful reading of the above observation of the learned Single Judge of Kerala High Court, it appears that unfettered and unbriddled power in the matter of taxation laws with wider application has been conferred upon the taxing authority. The statutes provide ample power to the Municipalities to make periodical revision of valuation of annual holding. Therefore, in the instant case, the action of the Municipal Authorities for revising valuation under section 186 of the C.M.C. Act, is neither improper, unfair and unjustified. 13. Now coming to the question of appealability of the order of assessment, the learned Counsel Sri Das Adhikary appearing for the C.M.C. Authorities has strongly relied upon a judgment reported in AIR 1987 SC 2211 where it has been held as follows: "Where no appeals were preferred against the assessments and no objections were filed against draft and provisional assessments, the assessments will not be liable to be set aside and in such cases, the writ petitions and appeals will to that extent stand dismissed." 14. In a Division Bench judgment reported in 1998 (1) CHN 492 in the case of C.M.C. & Ors. vs. Bala Bestos India Ltd. & Ors. it has been held as follows: "Having heard the learned Counsel for the parties we are of the opinion that in view of the fact that the writ petitioners have an efficacious alternative remedy, the learned Trial Judge erred in entertaining the writ applications particularly in view of the fact that the questions raised before the learned Trial Judge or before this Bench had not been raised in the writ applications. We may also take note of the fact that such questions and particularly the question of absence of jurisdiction relating to the mutation of the names of the petitioners or for that matter the authority or jurisdiction of the Assessing Officer to make assessment of composite rate in respect of each separate flat had not been questioned." 15. We may also take note of the fact that such questions and particularly the question of absence of jurisdiction relating to the mutation of the names of the petitioners or for that matter the authority or jurisdiction of the Assessing Officer to make assessment of composite rate in respect of each separate flat had not been questioned." 15. As regard non-communication of reasons in the impugned notices we may note that, in Assistant G.M., Central Bank of India vs. Municipal Corporation, Ahmedabad, reported in JT 1995 Vol. 4 SC 310, it is stated as follows: "We must deal with one another contention urged by Sri Pohinton Nariman. He submitted that the special notice issued in his case under Rule 15(2) of Chapter VIII of Schedule- A is totally devoid of any particulars or grounds upon which the assessment was sought to be enhanced. He relies upon the general proposition that a show cause notice must contain the relevant particulars and grounds sufficient to put the person concerned on notice of the proposed action and its basis. Absence of such particulars and grounds in such show cause notice, he submits, vitiates the special notice itself. The High Court has rejected the contention in the following words: Notice under section 15(2) is issued after entry in the assessment book has been made. Sub-rule (2) of rule 15 requires that the special written notice to the owner or the occupier shall specify the nature of such entry. In other words, the special notice must inform the owner about the entries mentioned in rule 9, clauses (a), (b) and (d) because the said rule 15 has to be read with rules 9 and 13. When a statute specified as to what should be the contents of a notice, and that is so specified in rule 15(2), the general principles enunciated by the aforesaid decisions and of the other High Courts would not be applicable. For the purposes of giving an opportunity to the owner• or an occupier to file a complaint, all that he has to be informed is what the commissioner has entered in the assessment book. One of the item, which is entered is the rateable value. The Commissioner is under no obligation to inform as to how the rateable value, which is entered in the assessment book, has been arrived at. One of the item, which is entered is the rateable value. The Commissioner is under no obligation to inform as to how the rateable value, which is entered in the assessment book, has been arrived at. It is for the owner to complain if he finds fixation of rateable value are well known. Ordinarily, a rateable value will be arrived at after particulars had been given by the owners or occupiers under rule 8 of the said Rules. On the receipt of the notice it will be for the complainant to lead evidence and prove as to what should be correct rateable value. A hearing is contemplated by rule 18 and if the assessee requires any classification with regard to the entry made in the assessment book we see no reason as to why this classification would not, ordinarily, be given. Be that as it may, rule 15(2) does not require, the giving of any particulars in addition to what is stated therein. The aforesaid decisions of various courts, therefore, can be of no assistance to the respondents. In view of the aforementioned authoritative pronouncement of the Apex Court, we are of the view that it was a fit case in which the learned Trial Judge ought not to have exercised to entertain the writ application, and ask the petitioners to avail statutory alternative remedy. In this view of the matter, we are of the opinion that the petitioners' remedy is to avail a statutory alternative remedy by preferring an appeal before the Municipal Assessment Tribunal as contemplated under sub-section (6) of section 189 of the Calcutta Municipal Corporation Act. We may note that the appeal which may be preferred by the writ petitioners, might have become barred by limitation, but we are sure keeping in view the fact that the petitioners were advised to file this writ application the Tribunal if any application for condonation of delay is filed, shall take into consideration the said and pass an appropriate order as regard condonation of delay in accordance with law." 16. Therefore, taking the cumulative effect of the observation made by the Apex Court as well as the Division Bench of this Court so also the learned Single Judge and on a careful consideration of the facts and circumstances, I hold this Court should not exercise its writ jurisdiction. Therefore, taking the cumulative effect of the observation made by the Apex Court as well as the Division Bench of this Court so also the learned Single Judge and on a careful consideration of the facts and circumstances, I hold this Court should not exercise its writ jurisdiction. In the above Division Bench decision, it has been held that no writ petition is maintainable against the observation of an assessment as regards the payment of Municipal Tax, but, however, with due reference to the order of the Division Bench which remitted back the matter to this Court, I have carefully examined the contention of both the parties in my humble view, the writ petitions failed on account of having not successfully established the grounds for my interference. 17. Mr. Saha, the learned advocate appearing for Ashoka Hotel has submitted that since the order in question does not contain good and sufficient reasons even though other alternative and efficacious remedy is available, yet such unreasoned order can be questioned in a writ petition. In support of the said submissions, he has relied upon a judgment reported in 1998(2) CLJ 87 but the ratio of the above Division Bench judgment is not applicable in view of the other Division Bench decision of the same Division Bench judgment. 18. Therefore, in the above conspectus of the case, I find the writ petitions are devoid of the merits which are, accordingly, dismissed without costs. Petition dismissed.