O. CHINNAPPA REDDY, J.

( 1 ) THE petitioner is the Andhra Pradesh State Electricity Board, a body corporate constituted under the provisions of the Electricity Supply Act, 1948. By its constitution it is endowed with "perpetual" succession and a comman seal in connection with it s duty of generation, supply and distribution of electricity. It has established several stations, sub-stations, offices and sub-offices, within the State of Andhra Pradesh. Several Gram Panchayats in the State of Andhra Pradesh have called upon the petitioner to pay profession tax under the Gram Panchayats Act. The respondents are two such Gram Panchayats. The Board claims that it is not liable to pay profession tax as it is neither a company nor a person with in the meaning of the expressions as used in section 72 of the Gram Panchayats Act. In any case, it is claimed that it is not liable to pay profession tax because it does not carry on any of it s operations with a profit motive and therefore cannot be said to transact any business so as to become liable to the levy of profession tax. The petitioner therefore seeks a writ of mandamus or other appopriate writ directing the respondents to refrain from de

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