1. These five writ petitions raise a common question. They have, therefore, been heard together, and are being disposed of by this single judgment. The Corporation of Calicut issued notices to the petitioners in all these cases under S.137 of the Kerala Municipal Corporations Act, 1961 (hereinafter referred to as the Act), assessing them to profession tax under S.113 in respect of income received by them by way of rent from buildings situate within the limits of the Corporation. The petitioners contend that the said assessments are illegal and without any authority of law.

2. The only provision in the Act which empowers the Municipal Corporation to levy profession tax is S.113. Sub-section (1) alone is relevant; and it reads,

"113. Tax on professions, arts, callings, business and appointments. (1) If the council by resolution determines that a profession tax shall be levied, every company which after the date specified in the notice published under S.100 transacts business in the city for not less than sixty days in the aggregate in any half-year; and every person who after the said date in any half-year,

(a) exercises a profession, art or calling or transacts business or