Not really surpassed per se, as Bathory was part of first wave black metal, which is pretty different from second wave, which is the 'typical' black metal sound (early Burzum/Satyricon/Enslaved/etc.). They are both great in their own ways.
I think it's pretty annoying that people who think metal (extreme metal in particular) isn't music, they don't realize the talent it takes to properly do various styles of harsh vocals (as in without wrecking your voice and being consistent in each range, some of them have been doing vocals like that for 20+ years and even sound better than ever at this point), use non-major scale melodies (cause you know, anything other than major scale isn't 'real melody' according to them), have songs longer than 3-4 minutes (even up to 10-20 minutes or longer) without typical verse/chorus structure that aren't super predictable and even use non-3/4 or 4/4 time that requires an attention span greater than a goldfish to understand, and so on. Complex/minimalistic structure != no structure. My roommate in college who was like this even said it's not possible for the musicians to remember how to play everything live, like music from bands like Suffocation, Necrophagist, and Augury, that was so laughable cause they are all pretty much flawless live.
Stuff like this would be the antithesis of music to people like that.
http://www.myspace.com/gaza (this is more grindcore-ish but fits with the others in being non-music lol)
Deathspell Omega (especially on Fas - Ite, Maledicti, in Ignem Aeternum, that's their most chaotic/obscure one)
And then of course there's the more atmospheric stuff that's also 'not music' like these.