MALIMATH, J. ( 1 ) THE petitioner has prayed in this writ petition for the quashing of the imposition of tax on advertisement boards carried by mechanical means such as motor cars and lorries as per the notice dt. 29-9-1965 issued under s. 98 (2) of the City of Bangalore Municipal Corporation Act, 1949, in pursuance of the resolution of the Corporation dated the 27th of July, 1965 and the demand notice dated the 12th of June, 1968 requiring the petitioner to pay a sum of Rs. 8,970-70 P. as advertisement tax in regard to the advertisements displayed on 159 MSRTC. buses running in the corporation area and health, cess. ( 2 ) RESPONDENT No. 1 which is the Corporation of the City of Bangalore constituted under the provisions of the City of Bangalore Municipal corporation Act, 1949 (hereafter referred to as the Act), is empowered by s. 97 (g) of the Act to levy tax on advertisements. S. 98 indicates the procedure to be followed for levying such a tax. S. 136 provides that the tax on advertisements may be imposed at such rates and in such manner and subject to such exceptions as the Corporation may, with the approval of the Government, by resolution determine. It further provides that the rates shall be subject to the maxima and minima laid down by the Government in this behalf. After following the prescribed procedure, the Corporation levied advertisement tax with effect from 1-11-1965, As required by S. 98 (2) of the Act, the Corporation published a notice bearing No. A2, pr. 2/61-62 dated the 29th of September, 1965 specifying the date from which and the rate at which the advertisement tax shall be levied. The schedule to the said notice contains 8 items in respect of which different rates of Advertisement tax have been prescribed. In this case, we are only concerned with item No. 5 of the said schedule which provides for levy of tax on advertisement boards carried by mechanical means such as motor cars and lorries. When a clarification was sought by the petitioner, the Corporation, by its letter dated the 29th of December, 1967, stated that under item No. 5 of the schedule of rates, tax is levied at the rate of Rs. 10 per bus per month and not per board. The Corporation issued a notice of demand dated 12th of June, 1968, demanding Rs. 10 per bus per month and not per board. The Corporation issued a notice of demand dated 12th of June, 1968, demanding Rs. 8,230 as advertisement tax from the petitioner in regard to the advertisements displayed on 159 MSRTC. buses running in the Corporation area as per the details given in the list attached to the said notice. It is not disputed that what has been claimed by the Corporation is advertisement tax at the rate of Rs. 10 per month for each bus on which the petitioner has displayed his advertiesments. ( 3 ) THE petitioner has challenged in this WP. the notice dt. 29th of september, 1965 issued under S. 98 (2) of the Act as well as the demand notice dated 12th of June, 1968. ( 4 ) THE first submission ot Sri K. Srinivasan, learned Counsel for the petitioner, is that though the Corporation is, under the Act, entitled to levy advertisement tax at a specified rate, it has actually not done so in this case. He invited our attention to the language of item No. 5 of the schedule which reads as follows : " Advertisements Boards carried by mechanical means such as motor car and lorries Rs. 10 per month or less. " because of the use of the expression "rs. 10 per month or less", it was submitted that instead of fixing the rate of tax as required by law, the corporation has only fixed the maximum limit. If it was intended to convey the meaning suggested by the petitioner, the Corporation would have used the expression "rs. 10 or less per month". As the expression "or less" hag been used immediately after the word ' month', it necessarily indicates that the said expression is intended to convey the meaning that the charge of Rs. 10 is for a month or a portion thereof. There is, therefore, no substance in the contention of Sri Srimvasan that no rate as such has been specified in clause 5. ( 5 ) THE next submission of Sri Srinivasan is that clause 5 is vague and ambiguous. He further submitted that if it is possible to give more than one interpretation to the said clause, the said clause being a charging provision, the interpretation which is most favourable to the tax payer should be accepted. ( 5 ) THE next submission of Sri Srinivasan is that clause 5 is vague and ambiguous. He further submitted that if it is possible to give more than one interpretation to the said clause, the said clause being a charging provision, the interpretation which is most favourable to the tax payer should be accepted. It was urged that it is possible to read clause 5 to mean that in respect of advertisement boards carried by mechanical means such as a motor car and lorries, tax has to be paid at Rs. 10 per advertisement board. Such an interpretation is not possible in view of the fact that the clause begins with the expression 'advertisements boards' and not 'advertisement board'. The use of the plural in the context clearly indicates that the rate is not for each board. If the rate was for each board, the same would have been clearly stated as in clause 4, which reads, "advertisements carried by sandwitch boardsmen Rs. 4 per board per month or less. " ( 6 ) IT was next suggested that it is possible to understand clause 5 to mean that Rs. 10 is the rate for all the advertisement boards carried on different vehicles belonging to the same individual. It is necessary to note that the tax is levied not on the business of advertisements but on the advertisements displayed. There is also nothing in the language of Cl. 5 which leads to the inference that the individual who uses different types of mechanical means for advertisements is taken as a unit. In our opinion, the only reasonable meaning to be given to clause 5 is that the mechanical means such as car or lorry is taken as a unit, irrespective of the number of advertisements carried on each such unit, As that is the only meaning that is possible in the context, we do not find any force in the submission of Sri Srinivasan that clause 5 suffers from any ambiguity or uncertainty. As, in our opinion, only one clear meaning is possible to give to clause 5, the question of applying the one most beneficial to the tax payer does not arise in this case. ( 7 ) THE last submission of Sri Srinivasan is that clause 5 is liable to be struck down as offending Art. 14 of the Constitution. As, in our opinion, only one clear meaning is possible to give to clause 5, the question of applying the one most beneficial to the tax payer does not arise in this case. ( 7 ) THE last submission of Sri Srinivasan is that clause 5 is liable to be struck down as offending Art. 14 of the Constitution. It was submitted that lack of classification has brought about inequality, resulting in violation of Art. 14 of the Constitution. He submitted that a classification ought to have been made on the following basis: (i) Type of vehicle used; (ii) the number of Boards carried on each vehicle; (iii) the locality where the vehicle is used; (iv) the size of the boards; and (v) the place of display i. e. , inside or outside the vehicle. It was urged that the aforesaid basis, having a direct relation to the utility or effectiveness of the advertisement, the same should have been adopted for classification. ( 8 ) IT is, no doubt, true that the guarantee of equal protection of laws applies to taxing statutes and provisions. Though guarantee of equal protection of laws extends to taxing statutes, it does not mean that every person should be taxed equally. In Kunnathat Thathunnu Moopu Nair v. State of Kerala, AIR 1961 SC 552 . The Supreme Court has pronounced as follows:"hence, if the Legislature has classified persons or properties into different categories, which are subject to different rates of taxation with reference to income or property, such a classification would not be open to the attack of inequality on the ground that the total burden resulting from such a classification is unequal. Similarly, different kinds of property may be subjected to different rates of taxation, but so long as there is a rational basis for the classification, Art. 14 will not be in the way of such a classification resulting in unequal burdens on different classes of properties. "in the light of the principles laid down by the Supreme Court, we have to examine the contention of the petitioner. ( 9 ) AS already mentioned, the Corporation is entitled to levy tax on advertisements under S. 97 (g) ot the Act. For the purpose of levying tax on advertisements, the Corporation has made a classification which is evident from the impugned notice issued under S. 98 (2) of the Act. ( 9 ) AS already mentioned, the Corporation is entitled to levy tax on advertisements under S. 97 (g) ot the Act. For the purpose of levying tax on advertisements, the Corporation has made a classification which is evident from the impugned notice issued under S. 98 (2) of the Act. The advertisements taxed by the Corporation have been classified into eight categories. The first category relates to advertisements on boardings, walls, sign posters and non-illuminated sky signs. The second category relates to advertisements suspended across streets and foot-paths. The third category relates to posters. The fourth category relates to advertisements carried by sandwitch boardsmen. The fifth category, the one with which we are concerned, deals with advertisements boards carried by mechanical means such as motor car and lorries. The sixth category pertains to illuminated advertisements and sky signs. The seventh category relates to advertisements exhibited on screens by means of slides and the last category deals with all advertisement films exhibited on the screen. Different rates have been specified for different classes of advertisements. The Corporation has, with the object of levying advertisements tax made a classification into eight categories. The said classification is made on the basis of types of advertisement, and the method of advertisements. The classification made on the basis of the type and method of advertisements cannot but be characterised as one made on a rational basis, having a just relation to the object sought to be achieved. It cannot be said in this case that inequality is brought about by lack of classification merely because classification has not been made on the lines suggested by Sri Srinivasan. That another basis of classification could have been adopted is no argument to hold that the classification made in this case is irrational or unreasonable. Art. 14 does not insist that the classification should be scientifically perfect or logically complete. The suggestion of Sri Srinivasan, at the highest, would mean that unequal burden falls on different persons. Failure to make further or sub-classification, as suggested by Sri srinivasan, may at the highest, result in mere incidental inequalities or the placing of unequal burden of different classes of persons. But that does not by itself lead to the inference that it is violative of Art. 14 of the Constitution, as long as the classification made into eight categories is on a rational basis. But that does not by itself lead to the inference that it is violative of Art. 14 of the Constitution, as long as the classification made into eight categories is on a rational basis. We are, therefore, of the opinion that there is no substance in the last contention of Sri Srinivasan. ( 10 ) FOR the reasons stated above, this writ petition fails and the same is dismissed. --- *** --- .