JUDGMENT : A.K. Jayasankaran Nambiar, J. The petitioners in WP(C).No.39273 of 2015, are the appellants before us aggrieved by the judgment dated 11.08.2023 of a learned Single Judge in the Writ Petition. 2. The brief facts necessary for the disposal of this Writ Appeal are as follows: The 1 st appellant is the owner of 14 Ares of land in Sy.No.4500A/1 (Re.Sy.No.351/9-2) of Eravipuram Village, Kollam. In the said property, the 2 nd appellant constructed a shed having an area of 739 Sq.Mts for running a business with an approved plan and licence from the respondent Corporation. As per the lease agreement entered into between the parties, the Corporation taxes and electricity charges in respect of the shed were to be honoured by the 2 nd appellant. The immediate cause of action for approaching the writ court was the service of Ext.P12 order by the Corporation, demanding property tax for the assessment years 2012-13, and 2013-14, in respect of the shed constructed by the 2 nd appellant. It would appear that, against the initial assessment to property tax completed in respect of the building for the assessment year 2012-13 the appellants were assessed to an amount of Rs.1,70,902/- per annum towards property tax. It is not in dispute that the said amount was paid by the appellants under protest, and thereafter, they preferred an appeal before the First Appellate Authority. For the assessment year 2013-14, the appellants were again assessed to property tax at the same figure of Rs.1,70,902/- per annum. In an appeal preferred by them before the First Appellate Authority, however, the First Appellate Authority relied on a Government order dated 27.04.2015, which envisaged an enhancement of property tax with effect from 01.04.2013, and directed that the property tax to which the appellants would be liable would be in an amount of Rs.89,419/- per annum. 3. As far as the appellants were concerned, the Government order dated 27.04.2015 (with effect from 01.04.2013) resulted in a revisiting of the assessment done in respect of the buildings in question and effectively reduced the property tax payable in respect of the building. 3. As far as the appellants were concerned, the Government order dated 27.04.2015 (with effect from 01.04.2013) resulted in a revisiting of the assessment done in respect of the buildings in question and effectively reduced the property tax payable in respect of the building. While the said reduction of tax ought to have enured to the benefit of the appellants even in respect of the assessment year 2012-13, for reasons best known to the Assessing Authority, in Ext.P12 order, the benefit of the reduced rate of tax was confined only to the assessment year 2013-14 and not to the assessment year 2012-13. This resulted in an anomalous situation where the appellants had to pay property tax at the rate of Rs.1,70,902/- per annum for the assessment year 2012-2013 whereas they were liable to pay, and paid, property tax at the rate of Rs.89,419/- per annum for the assessment year 2013-14 and subsequent years, on the same property. It is impugning Ext.P12 order that brought about the said anomaly, and Ext.P15 demand notice that raised exorbitant demands on the appellants, that they approached this Court through the Writ Petition aforementioned. 4. The learned Single Judge, who considered the Writ Petition found that in as much as the appellants had been charged a lesser rate with effect from 2013-14, there was no cause for grievance as far as the appellants were concerned and further, since the Government Order dated 27.04.2015 (with effect from 01.04.2013) had not been assailed by the appellants, the appellants could not be seen as aggrieved by the said Government Order. The Writ Petition was therefore dismissed. 5. Before us, it is the submission of Sri. V. Varghese, the learned counsel for the appellants, that the learned Single Judge erred in assuming that the appellants were in fact aggrieved by the terms of the Government Order dated 27.04.2015. He would submit that as a matter of fact, the Government order conferred a benefit on the appellants and it was because of the terms of the said Government Order that the First Appellate Authority chose to reduce the property tax payable in respect of the building put up by the appellants for the assessment year 2013-14. He would submit that as a matter of fact, the Government order conferred a benefit on the appellants and it was because of the terms of the said Government Order that the First Appellate Authority chose to reduce the property tax payable in respect of the building put up by the appellants for the assessment year 2013-14. It is pointed out that when the Government Order in question proposed an enhancement of tax, the Corporation could not have demanded a higher tax for the immediate preceding year, namely, 2012-13, from the appellants. We have also heard Smt. Nithya V.D, the learned counsel on behalf of the respondent Corporation. 6. On a consideration of the rival submissions, we find force in the contention of the learned counsel for the appellants that, consequent to the revision effected with effect from 01.04.2013, the appellants could not have been put in a position where, consequent to an enhancement of property tax that was envisaged by the revision order, they ended up paying lower tax for the future period, but a higher rate of property tax for the immediate proceeding year, prior to the revision. In our view, the finding in Ext.P12 order that the benefit of the reduction of tax would not enure for the assessment year 2012-13 is a patent mistake and illegal, and liable to be set aside. 7. We also note that the appellants had paid an amount of Rs.1,70,902/- towards property tax during the assessment year 2012-13, when the actual amount that was payable for the whole year as per Ext.P12 order would have been only Rs.89,419/-. The appellants would, therefore, be entitled to a refund of Rs. 81,483/-, the differential tax paid by them for the assessment year 2012-13, (Rs.1,70,902/- - Rs.89,419/- = Rs.81,483/-). Since we have found that the amount of Rs.89,419/- per annum is the property tax payable for the assessment year 2012-13, we are of the view that instead of refunding the said differential amount (Rs.81,483/-) to the appellants at this stage, the respondent Corporation may adjust the said amount towards future dues of property tax in respect of the same building belonging to the appellants. The Writ appeal is, therefore, allowed by setting aside the impugned judgment of the learned Single Judge, allowing the Writ Petition by quashing Exts.P12 and P15 to the extent indicated above, and by finalising the property tax liability of the appellants for the assessment year 2012-13 and 2013-14 in accordance with the findings in this judgment.