Madhavan Nair, J.

1. The plaintiff is the appellant, This second appeal arises out of a suit instituted by the plaintiff for the recovery of professional tax of a sum of Rs. 119-12-0 together with interest alleged to have been collected from him wrongfully by the defendant, the Taluk Board of Chicacole represented by its President. The Board assessed the appellant to a professional tax on the ground that he was carrying on money-lending business as his profession. His case is that he is not carrying on the profession of a money-lender and that his accounts, if inspected, would prove his plea; but that the President of the Board refused to look into them. Without examining the merits of his contention, the lower Courts dismissed the suit, as barred by Section 228, Local Boards Act 14 of 1920. Clause (2) of this section expressly bars a suit to recover any sum of money collected under authority of this Act....provided that the provisions of this Act have been in substance and effect complied with,

2. The plaintiffs argument is that an examination of his accounts would show that he is not carrying on the profession of a money-lender, and that if the tax is collected from a perso