Reilly, J.

1. These cases refer to two Banks which have been registered under the Co-operative Societies Act, namely," the Madras Central Urban Bank, Limited, and the Madras City Co-operative Bank, Limited, both of which carry on their operations in Madras. The Commissioner of the Corporation of Madras demanded profession tax from these two Banks tinder Section 111 of the Madras City Municipal Act of 1919. Under that section only persons who are not liable to companies tax under Section 110 of the Act are liable to profession tax. Both the Banks objected to the Commissioners demands, at that stage apparently maintaining that they were liable neither to profession tax nor to companies tax. They appealed to the Standing Committee of the Corporation, which rejected their appeals. Then, under Rule 15 of SchIV of the City Municipal Act they appealed to the Court of Small Causes and at that stage contended that, if they were liable to be taxed at all, it was under Section 110 of the Act to companies tax, not to profession tax. The learned Chief judge, who heard those appeals, found that the two Banks were liable to pay companies tax under Section 110 but not profession tax under S