Judgment :- 1. The Regional Manager, Food Corporation of India, Trivandrum, is the petitioner in both these Writ Petitions. The food Corporation was called upon by the Puthupariyaram Panchayat in Palghat District and the Muzhappilaogad Panchayat in Cannanore District to pay profession tax to those Panchayats, on the ground that the Corporation was transacting business within their local limits In response to the notice issued to the Corporation in that behalf by the two Panchayats the Corporation raised the objection that, it is not liable to be assessed to profession tax under S.69 of the Kerala Panchayats Act. That object was over-ruled by the Panchayat and assessment orders were passed. Against those orders the Corporation unsuccessfully appealed to the Deputy Directors of Panchayats having jurisdiction over the respective areas and, later revision petitions were also filed before the State Government. The State Government also took the view that the contention raised by the Food Corporation was not tenable and, accordingly, rejected those revision petitions. The matter was, thereupon, taken to this Court by the Food Corporation of India, by filing these two Writ Petitions challenging the orders of assessment to profession tax passed against it by the Executive Officers of the two Panchayats and the Appellate and Revisional orders confirming the same. 2. The question raised before us lies in a narrow compass and it relates to the interpretation to be placed on sub-section (1) of S.69 of the Kerala Panchayats Act. That provision reads: "The profession tax shall, subject to such rules as may be prescribed be levied every half year in every Panchayat area on (i) every company which transacts business in such Panchayat area for not less than sixty days in the aggregate in that half year; and (ii) every person who, in that half year (a) exercises a profession, art or calling or transacts business or holds any appointment, public or private (i) within such Panchayat area for not less than sixty days in the aggregate, or (ii) without such Panchayat area but who resides in it for not less than sixty days in the aggregate, or (b) resides in such Panchayat area for not less than sixty days is the aggregate and is in receipt of any pension or income from investments". It is argued on behalf of the Writ Petitioner that sub-section (1) authorises the levy of profession tax only on companies and natural persons, and in as much as the Food Corporation of India is neither a company nor a natural person, it is not liable to be subjected to the levy of the said tax. 3. A similar contention was raised before this Court in K.S.E Board v. Cannanore Municipality (1972 KLT. 265). In that case, the Kerala State Electricity Board raised the plea that, it is not liable to be assessed to profession tax under S.110 of the Kerala Municipalities Act. 1960, (Act XIV of 1961), which, in regard to all material aspects, is identical in terms with subsection (1) of S.69 of the Kerala Panchayats Act. Isaac J, rejected that contention and held that, ordinarily, the word 'person' used in a statute includes a natural person as well as a juristic person, and, since the Kerala State Electricity Board is a juristic person, it is liable to be subjected to the levy of profession tax under S.110 of the Kerala Municipalities Act. The Kerala Panchayats Act does not contain a definition of the expression'person'. We are in respectful agreement with the view expressed by Isaac J., that in the absence of any intention to the contrary contained in the particular statutory provision the expression ‘person' used therein would, ordinarily, include not merely natural person but also a juristic person. It is, however, contended by the learned Advocate appearing on behalf of the Writ Petitioner that, the explanation to S.72 of the Act, which states, "in this section person includes an institution, firm, company or corporation" clearly indicates that the Legislature did not intend the expression ‘person' occurring in the other provisions in the Act to include institutions, firms, companies or corporations. Counsel points out that, otherwise, it would have been wholly unnecessary for the legislature to incorporate the explanation aforementioned in S.72 of the Act We are unable to agree with this argument. In our opinion, the explanation to S 72 can only be regarded as a provision incorporated by way of abundant caution, in order to obviate or remove any uncertainty or doubt as to whether the exemption that the Government is empowered to give under Sub-s. (2) thereof can be granted in respect of artificial persons also such as firms, companies, corporations etc. Sub-section (6) of S.69 makes it clear, beyond doubt, that the legislature contemplated that, profession tax should be levied, under the said section, not merely from companies and natural persons but also from firms, associations, Joint Hindu families etc. Sub-section (6) of S.69 is in the following terms. "The profession tax leviable from a firm, association, joint Hindu family or Marumakkathayam tarwad or Aliyasanthana family may be levied from the agent of the firm or association or manager of the family or tarwad, as the case may be." Hence, far from there being any indication in the Section of a legislative intent to restrict the meaning of the expression ‘person' only to natural persons, the provisions of sub-section (6) unmistakably show that the legislature intended that profession tax should be levied not only from companies and natural persons, but also from artificial or juristic persons like Joint Hindu families, Marumakkathayam tarwards and even firms and associations. Such being the position, we do not find it possible to uphold the contention of the Writ Petitioner that the Food Corporation of India, which being a body corporate constituted under the Food Corporation of India Act is undoubtedly a juristic person, is not liable to be assessed to profession tax under S.69 of the Kerala Panchayats Act. The Writ Petitions are, therefore, devoid of merits and they will accordingly, stand dismissed. The parties will bear their respective costs. Dismissed.