The judgment of the Court was delivered by

P. A. CHOUDARY J. - These two writ petition raise questions about the meaning and scope of section 5 of the Andhra Pradesh Entertainments Tax Act, 1939. Under section 4 of that Act, entertainment tax is leviable on the gross collection of every show held in the theatres specified in column (2) of the table appended to that section and located in the local area specified in the corresponding entry in column (1) of the table. Under section 5, the option is given to the theatre owners to pay tax in lieu of tax payable under the aforesaid section 4. The tax so payable is specified in the table given to section 5. Section 5 says :

"In lieu of the tax payable under section 4, in the case of the entertainments held in the theatres specified in column (2) of the table below and located in the local areas specified in the corresponding entry in column (1) of the said table, the proprietor thereof may, at his option and subject to such conditions as may be prescribed, pay the amount of tax to the State Government every week as specified in the corresponding entry in column (3) thereof."

Now in the table to section 5, entry (a) deals with municipal corporations and Secunderabad cantonment area and contiguous area of 6 kms. We are not directly concerned with that area. We are concerned with the next entry (b), viz., selection grade municipalities and the contiguous area of 6 kms. thereof. The question is as to the meaning of the contiguous area of 6 kms. Now the authorities in this case are attempting to collect tax under section 5 from these two writ petitioners at the rate appropriate for a theatre situated within the selection grade municipalities and the contiguous area of 6 kms. thereof. Undoubtedly these two theatres are situated within 6 kms. of Rajahmundry which is a selection grade municipality. But these two petitioners have their theatres situated within a third grade municipality called Kovvur which is dealt with by entry (f) of that table. The rate of tax payable by the theatres located within the selection grade municipalities and the contiguous area of 6 kms. is much higher than the rate of tax payable by the theatres situated within the third grade municipalities and the contiguous area of 2 kms. thereof. The petitioners, therefore, contend that their theatres should be charged under entry (f) and not entry (b).

The case of the authorities is that Kovvur municipality which is a third grade municipality within whose territorial limits these two theatres have been located, is situated within the contiguous area of 6 kms. of Rajahmundry municipality which is a selection grade municipality and for that reason these theatres should pay the tax at a higher rate which is mentioned in item (b). The question whether the petitioners are liable to pay entertainment tax at that higher rate appropriate to the selection grade municipality or at a lower rate appropriate to a third grade municipality, depends upon the meaning of the words "contiguous area of 6 kms." Literally read the two entries are conflicting and overlapping with one another. Kovvur is within 6 kms. of Rajahmundry municipality and would apparently fall within entry (b). But Rajahmundry is also within 6 kms. of Kovvur municipality and would fall under entry (f). A literal reading of the statutory provisions can only result in confusion. No court can read a statute as working at cross purposes and conflicting purposes. The provisions cannot obviously be given that meaning. For this reason alone these entries call for reconciliation. The only reasonable way to avoid this mutually destructive war between entry (b) and entry (f) and to bring about peace between them is to read the words "contiguous area" as referring not to a contiguous area which is under the jurisdiction of another local body. In other words, where the contiguous area of a municipality is itself a part of a duly constituted municipality, the rate of taxa