1. These two revisional applications raise a common question and the question raised is about the meaning to be given to the expression rent as occurring in Rule 7(1) of the Taxation Rules in Chapter VIII of the schedule to the Bombay Provincial Municipal Corporations Act, 1949.

2. The applicants are owners of certain tenements which were let out to different tenants. These tenements are situate within the limits of the Municipal Corporation of Ahmedabad and the rateable value of these tenements for the year 1952-53 had to be fixed. It appears that there was a covenant in a lease executed between the applicants and their tenants whereby the tenants were to pay the rent as well as the Municipal taxes to their landlords. The Municipal Corporation calculated the rateable value, treating the rent and taxes as rent recovered by the landlords.

3. The applicants, feeling aggrieved by the aforesaid method of calculation, contended that they were entitled to deduct the amount of taxes as the applicants were merely the agents of the Corporation when they collected the taxes from their tenants. They took the contention that the rateable value should, therefore, be fixed on the basis of