Jackson, J.

1. Petitioner seeks to revise the judgment and decree of the District Judge of Ganjam in Appeal Suit No. 51 of 1926 dismissing her suit against the respondent the President of the Taluk Board of Chicacole.

2. The petitioner was assessed to profession tax from 1921 to 1923 and sued to recover the amount collected under that assessment Rs. 440-2-0 on the ground that as a matter of fact she had not practised any profession for that period within the limits of the Taluk Board.

3. The learned District Judge has held that the petitioners suit is barred by the provision of Section 228 (2) Madras Local Boards Act 1920. "No suit shall be brought in any Court to recover any sum of money collected under the authority of this Act...provided that the provisions of this Act have been in substance and in effect complied with."

4. The provisions for collecting profession tax will be found in Section 93 and Schedule IV of the Act. The Local Board prepares and keeps books showing the persons liable to the profession tax, Schedule IV 5. Persons liable to the tax are assessed (IV 9) and an appeal lies to the Local Board (IV 27) both against assessment and the levy of the tax. If the Lo