JAYANT PATEL, J.

( 1. ) AS in all the appeals common questions arise for consideration, they are being considered by this common judgment.

( 2. ) THE relevant facts are that the officers of the respondent-Corporation fixed the Gross Ratable Value (G.R.V.) of the concerned premises at the different rates for the concerned respective assessment years. As the assessees concerned, who are the respondents herein, were aggrieved by the assessment made by the officers of the respondent-Corporation for the concerned years, they preferred respective Municipal appeals before learned Small Causes Judge, Ahmedabad. Learned Judge, vide impugned judgments and order in all the appeals, found that in respect of earlier year, as notice contemplated under Rule 15(2) of the Taxation Rules (the Rules) was not served, the assessment was quashed and set aside. It was further found by the learned Judge that thereafter once the assessment for the earlier year was quashed and set aside, thereafter if any entry was to be made in the assessment book, it was required for the officers of the Corporation to issue notice under Rule 15(2) of the Rules afresh, if such notice has not been issued, the G.R.V. fixed even in the present cases would be required to be quashed. Under the circumstances, the learned Judge has quashed and set aside fixation of G.R.V. and consequently it becomes a case for zero tax assessment of the concerned year. All those impugned judgments are the subject-matter of the present appeals before us.

( 3. ) WE have heard Mr. Tanna, learned Senior Counsel, with Mr. Bhatt, learned Counsel for the appellants. In First Appeal Nos. 1735, 1722, 1730, 1737, 5858, 5864 and 5868 all of 1995, the respondents have refused to accept the service, whereas in First Appeal No. 3073 of 1996, Mr. Kinariwala, learned Counsel, has filed appearance for the respondent and in First Appeal No. 3097 of 1996, Mr. Bhagat, learned Counsel, has filed appearance for the respondent.

( 4. ) MR. Tanna contended that in all the appeals the impugned judgments and order of learned Small Causes Judge, Ahmedabad are ex-facie erroneous inasmuch as they have resulted into zero tax assessment of all the premises, which is contrary to the decision of this Court reported in the case of Municipal Corporation of the City of Ahmedabad v. Oriental Fire and General Insurance Co. Ltd., 1994 (2) GLR 1498 and he further submitted that on the contrary if the entry has continued in the assessment book and no complaints/objections have been filed, and thereafter bills are issued by the Corporation to the assessee, the appeals could not be maintained against the bill. MR. Tanna further submitted that as per the decision of this Court in the case of Municipal Corporation of the City of Ahmedabad (supra), the appeal was available against the assessment only on the disposal of the complaint/objections against the assessment and if the person concerned has failed to lodged objection, after the Corporation has completed the procedure under Rule 15(1) of the Rules by publication of the notice in the newspaper, it would be an end of the matter and the appeal would not be competent before the learned Small Causes Judge. It was also contended that as per the observations made by this Court in the above referred judgment, at the most, it would be a case where the person may file a writ petition under Arts. 226/227 of the Constitution of India. Therefore, it was submitted that neither the appeal was competent nor the learned Small Causes Judge could I quash the whole assessment by creating a situation of zero tax assessment in the concerned order. It was also submitted that the learned Small Causes Judge, as per the scheme of the Act and observations made by the aforesaid decision, ought to have fixed the G.R.V. of the concerned premises for the concerned year. Since the same has not been done, there is material error in exercise of power by the learned Small Causes Judge, which calls for interfer