S. K. NAYAK, J. ( 1 ) THE petitioner is a government Company, owned and managed by the Government of India and is under the control of Department of Atomic Energy. ( 2 ) IN this writ petition, the petitioner company has sought for a writ of certiorari to quash the proceedings of the Regional director-cum-Appellate Commissioner, municipal Administration, Hyderabad, the 2nd respondent herein dated 23. 12. 1998 dismissing the appeal filed by the petitioner and also the consequential order passed by the Kapra Municipality represented by its commissioner, the 1st respondent herein, in letter No. KM/3477/88, dated 26. 12. 1998. ( 3 ) THE present writ petition has had a long, but, chequered career. The appeal decided by the 2nd respondent impugned in this writ petition admittedly relates to the house Tax determination relating to the assessment years 1988-89 and 1989-90. The 1st respondent initially issued a Special notice fixing the property tax at rs. 21,30,840/- on the properties owned by the petitioner-company under the provisions of the A. P. Municipalities Act, 1965. The petitioner objected to the assessment fixing the actual rental value at Rs. 87,68,916/- and computing the tax liability thereupon at rs. 21,30,840/-, inter alia, contending that certain buildings covered are used for education purposes, hospitals, libraries, dispensaries and play grounds and those properties have to be excluded from the purview of the taxation. It was also contended by the petitioner-company that earlier the tax was fixed at Rs. 1,30,000/- per annum, there was no jurisdiction for enhancing it to Rs. 21,30,840/ -. However, rejecting the above contentions of the petitioner-company, the 1st respondent reduced the tax liability of the petitioner marginally and confirmed the levy of tax at rs. 21,26,472. 70. Aggrieved by the said action of the 1st respondent, the petitioner filed Writ Petition No. 9212 of 1989 in this court. This Court disposed of that writ petition by order dated 7. 9. 1989 directing the 1 st respondent to furnish the reasons on the basis of which it proposed to fix the annual rental value at Rs. 87,68,916/-, after giving reasonable opportunity to the petitioner. In pursuance of the above direction of this Court in Writ Petition no. 9239 of 1989, the 1st respondent sent a statement to the petitioner explaining as to how the annual rental value was to be fixed. 87,68,916/-, after giving reasonable opportunity to the petitioner. In pursuance of the above direction of this Court in Writ Petition no. 9239 of 1989, the 1st respondent sent a statement to the petitioner explaining as to how the annual rental value was to be fixed. On receipt of that statement, the petitioner filed a detail written brief. The 1st respondent again, according to the petitioner, ignoring the objection raised in the written brief, confirmed the levy and fixed the property tax payable at Rs. 21,26,472. 70ps. by his order dated 13. 3. 1990. Against the said order, the petitioner preferred an appeal under Rule 22 (1) of the Schedule II to the a. P. Municipalities Act to the appellate commissioner, the 2nd respondent herein. However, at the same time, the petitioner also filed a writ petition, numbered as Writ petition No. 5244 of 1990 in this Court seeking for a direction to the appellate authority to dispose of the appeal on merits without insisting on the payment of the disputed tax. This Court disposed of that writ petition by order dated 23. 4. 1990 and directed that appellate authority to dispose of the appeal on merits on the petitioner depositing a sum of Rs. 4. 00 lakhs within a month. The contentions earlier advanced before the 1st respondent were reiterated before the appellate authority. The appellate authority, however, dismissed the appeal filed by the petitioner and that led to the petitioner filing Writ Petition No. 16578 of 1990 in this Court. The said writ petition was disposed of by this Court by judgment and order dated 28. 4. 1998, quashing the order passed by the appellate authority. After the disposal of the Writ Petition No. 16578 of 1990, the 2nd respondent again heard the appeal and passed the order dated 23. 12. 1998 dismissing the appeal. While doing so, the 2nd respondent appellate authority has not only upheld the imposition of tax of rs. 23,86,674/- for the year in question, i. e. for 1989-90, but also levied the tax for the period with effect from 1. 4. 1989 to the date of the order. Hence, this writ petition assailing the validity of the order passed by the 2nd respondent. 23,86,674/- for the year in question, i. e. for 1989-90, but also levied the tax for the period with effect from 1. 4. 1989 to the date of the order. Hence, this writ petition assailing the validity of the order passed by the 2nd respondent. ( 4 ) LEARNED Counsel appearing for the petitioner would firstly contend that the impugned orders suffer from an error apparent on its face, whereas the subject- matter of appeal was restricted to the tax liability of the petitioner for the assessment year 1988-89, the appellate authority without authority of law proceeded to determine the tax liability of the petitioner in respect of the entire period from 1. 4. 1989 to the date of the order. Secondly, the learned counsel would maintain that even the order of the appellate authority with regard to the determination of the tax liability of the petitioner in respect of the assessment year 1988-89 cannot also be sustained, because, the appellate authority has completely ignored the earlier directions issued by this Court in writ proceedings. ( 5 ) ON the other hand, Mr. V. Viswanatham, learned Standing Counsel for the Municipality would strenuously contend that no exception can be taken to the impugned order passed by the appellate authority because the appellate authority has undoubtedly the power to determine the tax liability of the petitioner even for the period commencing from 1. 4. 1989 to the date of the order. Learned Standing Counsel would otherwise support the impugned order. ( 6 ) AFTER hearing the learned Counsel, we find that the impugned orders are vitiated on account of error apparent on its face. It is too primarily to state that the appellate authority, generally speaking, cannot go beyond the subject-matter of appeal and that in deciding the appeal, it cannot decide or determine the liability of the appellant which falls outside the purview of the appeal. However, learned Standing counsel for the Municipality does not agree with this proposition, but has not referred to any provisions of the Municipalities Act, or the Rules or Regulations made thereunder, which grant the power to the appellate authority to go beyond the subject matter of the appeal and fix the tax liability of the petitioner even in respect of the period commencing from 1. 4. 1989 to the date of the order. 4. 1989 to the date of the order. ( 7 ) IN that view of the matter, on first principle, the order of the appellate authority determining the tax liability of the petitioner for the period from 1. 4. 1989 to the date of the order should be held to be one without authority of law and void. ( 8 ) SECTION 81 of the A. P. Municipalities act, 1965 (for short the Act ) deals with the powers of the Council of the Municipality to determine the property tax, among other kinds of tax, whereas Section 87 deals with the method of assessment of property tax. ( 9 ) A careful reading of the provisions of Section 87, particularly, sub-section (3) thereof, would clearly indicate that it is the commissioner of Municipality, who has to determine and raise the tax in respect of each assessment year in pursuance of the determination that may be made by the council of the Municipality under Section 81 read with Section 83 of the Act. It is not even the case of the respondent Municipality, as could be seen from the counter-affidavit filed by it, that the Commissioner has determined the tax liability of the petitioner- company commencing from 1. 4. 1989 to the date of the order. Alternatively, should it be noticed that even assuming that the commissioner has determined house tax liability of the petitioner-company for the aforementioned period, even then, there was no occasion for the 2nd respondent, appellate authority to interfere with that determination, unless in the form of an appeal relating to such assessment of lands before him for adjudication. It is nobody s case that the appeal filed by the petitioner-company before the 2nd respondent had something to do with the determination of the tax liability of the petitioner in respect of the period commencing from 1. 4. 1989 to the date of the order. ( 10 ) LOOKING from any angle, the impugned order insofar as it determines the tax liability of the petitioner-company for the period commencing from 1. 4. 1989 to the date of the order, cannot be sustained and it should be declared as a nullity. ( 11 ) THIS takes us to the second contention of the learned Counsel for the petitioner. 4. 1989 to the date of the order, cannot be sustained and it should be declared as a nullity. ( 11 ) THIS takes us to the second contention of the learned Counsel for the petitioner. After perusing the order of the 2nd respondent, we should state that the directions issued by this Court in earlier writ proceedings to which reference is made supra, have not been complied with by the 2nd respondent. The contentions raised by the petitioner-company in its written brief are not dealt by the 2nd respondent in the manner in which a quasi-judicial authority like the 2nd respondent is expected to consider. Since the order of the 2nd respondent is held to be illegal and without authority of law, the consequential order passed by the 1st respondent should also fall to the ground and is liable to be declared as invalid. ( 12 ) IN the result and for the foregoing reasons, we cannot sustain the impugned orders. Accordingly, the writ petition is allowed and the impugned orders are quashed. The proceedings shall stand remitted to the 2nd respondent appellate authority to dispose of the appeal in accordance with law and in the light of this judgment. No costs.