Wallace, J.

1. The decision in this case turns on the interpretation of Section 93 of the District Municipalities Act. The Municipal Council of Madura has demanded profession tax from the Receiver of the Sree Meenakshi Devasthanam in Madura on income received by him from investments of surplus devesthanam funds. The devasthanam paid under protest and instituted this suit for a declaration that it was not liable for the tax and for an injunction to prevent collection. The sum in the suit is trifling, a matter of Rs. 2, but the legal and fiscal question involved is obviously of general importance.

2. So much of the decision in the case will turn on the exact wording of Section 93 (1) that it is better to quote it in full. Section 93, Sub-section 1:

If the chairman publishes a notification under Section 80, that a profession tax shall be levied, every person, not liable to the companies tax, who, within the Municipality and for the period laid down in Section 95, exercises after the date specified in the said notification a profession, art, trade or calling or holds any appointment public or private, or is in receipt of any pension or income from investments or money lending or a