S.J. Mukhopadhaya, J.

1. The appellant-writ petitioner having unsuccessfully challenged the vires and validity of Rule 14 of Schedule IV of Part V of the Taxation Rules of the Chennai City Municipal Corporation Act, 1919, has preferred this Writ Petition.

2. The main plea taken is that Rule 14 of Schedule IV of Part V of the Taxation Rules of the Chennai City Municipal Corporation Act, 1919, is null and void, as it does not provide for waiver or exemption for entertaining an appeal before the Taxation Appeal Tribunal in relation to the property tax.

3. The learned single Judge upheld the Rule as intra-vires, but directed the second respondent to issue notice to the assessee and grant an opportunity of personal hearing and follow the principles of natural justice before enhancing the property tax.

4. We have heard the learned counsel appearing for the parties and perused the records and noticed the relevant provisions.

5. Chapter V of the Chennai City Municipal Corporation Act, 1919, deals with Taxation. While Section 99 of the said Act relates to description and class of property tax, Section 100 stipulates the method of assessment of property tax. Under Section 138 of