JUDGMENT : H.N. SETH, J. 1. By this petition under Article 226 of the Constitution Petitioner State Bank of India challenges the validity of the proceedings for assessment and recovery of circumstances and property tax imposed by the Zila Parishad, Gorakhpur upon its various branches located within the jurisdiction of that Zila Parishad. 2. Petitioner State Bank of India is a corporate body having its central office at Bombay. It maintains various branches at various places in the country and also in other countries. The general superintendence and direction of affairs of the business of the Petitioner is entrusted to the Petitioner's Central Board, constitution of which is governed by Section 19 of the State Bank of India Act. It has its local head offices at Bombay, Calcutta, New Delhi, Madras, Ahmadabad. Hyderabad, Kanpur, Patna and Bhopal which control the affairs of the offices and sub-offices etc., situated within their respective regions. The Petitioner Bank has a number of branches and sub-offices in the district of Gorakhpur located within the jurisdiction of Zila Parishad, Gorakhpur. For the years 1970-71 to 1974-75 Zila Parishad, Gorakhpur assessed circumstance and property tax on some of the branches of the Petitioner Bank located within its jurisdiction at the rate of Rs. 2000/- per year and has also issued notices to other branches of the Petitioner for assessing them accordingly. It has also issued notices of demand requiring various branches of the Petitioner to pay the circumstance and property tax so assessed against them. 3. By means of this petition, the Petitioner has challenged the validity of assessment of circumstance and property tax against its branches inter alia on the ground that under the Uttar Pradesh Kshetra Samitis and Zila Parishad Adhiniyam, Zila Parishad, Gorakhpur could assess and impose circumstance and property tax only upon the Petitioner, and that it had no jurisdiction to assess tax on its individual branches. According to it, in substance the Zila Parishad, Gorakhpur, which has imposed a tax amounting to Rs. 2,000/- against each of its branches, is seeking to recover an amount which is far in excess of Rs. 2,000/-(maximum of the limit to which circumstance and property tax can be imposed under the Constitution) from the Petitioner. According to it, in substance the Zila Parishad, Gorakhpur, which has imposed a tax amounting to Rs. 2,000/- against each of its branches, is seeking to recover an amount which is far in excess of Rs. 2,000/-(maximum of the limit to which circumstance and property tax can be imposed under the Constitution) from the Petitioner. The stand taken by the Zila Parishad, however, is that each of the said branches of the State Bank of India is carrying on separate and independent business within its jurisdiction hence each one of them is liable to be assessed to circumstance and property tax under the provisions of the Uttar Pradesh Kshettra Samiti and Zila Parishad Adhiniyam, separately and that its action in assessing each of the branches of the State Bank of India separately and in recovering the circumstance and property tax so assessed against them, is within its jurisdiction. 4. Section 119 of the Uttar Pradesh Kshettra Samiti and Zila Parishad Adhiniyam (hereinafter referred to as the Act) enables the Zila Parishad to impose tax on circumstances and property. Section 121 of the Act then empowers the Zila Parishad to impose tax on circumstances and property subject to the conditions and restrictions mentioned below; namely, (a) the tax may be imposed on any person residing or carrying on business in the rural area; provided that such person has so resided or carried on business for a total period of at least six months in the year under assessment; (b) no tax shall be imposed on any person whose total taxable income is less than six hundred rupees per annum; (c) the rate of tax shall not exceed three Naye Paise in the rupee on the total taxable income; and (d) the total amount of tax imposed on any person shall not exceed such maximum, if any, as may be prescribed by rule. 5. It will thus be seen that according to Section 121 of the Act the liability to be assessed on circumstances and property tax is that of a person who has been residing or carrying on business in the rural area for a total period of at least six months in the relevant year and whose total income is not less than six hundred rupees per annum. The total liability for such tax for a particular year can in no case exceed the amount prescribed by the rule, which in this case happens to be rupees 2,000/-. As held by the Supreme Court in the case of R.R. Engineering Co. v. Zila Parishad Bareilly 19 ALJ 403 the circumstance and property tax levied u/s 119 of the Act is a tax on status of an individual. It is true that in determining the status of an individual the income derived by him may, if necessary along with other factors, be taken into consideration. The status of the individual has to be looked at as a whole. Mere fact that a person residing or carrying on business within the jurisdiction of a town area carries on a number of business activities, independent of each other, it does not mean that he has different status in relation to each of such business activities dependent upon the income which he derives from each such business. For the purposes of circumstances and property tax his status as a whole will have to be determined and it will depend upon the income which the person derives from all the businesses that he is carrying on within the jurisdiction of the Zila Parishad. 6. In the case before us it is the State Bank of India which is a corporation and a juristic person, which carries on the business within the jurisdiction of Zila Parishad, Gorakhpur through its staff posted to various branch-offices. Various | branch-offices through which the State Bank of India carries on its business cannot be described as persons who carry on the business. In our opinion it is either a natural person, that is, a human being or juristic person which alone is capable of carrying on business so as to be subjected to circumstance and property tax under the Act. A branch office of the State Bank of India is neither a natural person nor is it a juristic person. Accordingly it is not capable of carrying on business on its own. When a branch-office is established it is the State Bank of India which is a juristic person which carries on business in the area through the staff posted or attached to the branch-office. Accordingly it is not capable of carrying on business on its own. When a branch-office is established it is the State Bank of India which is a juristic person which carries on business in the area through the staff posted or attached to the branch-office. Any direction to the branch office to pay a tax is in substance a direction to the State Bank itself to pay the same. Accordingly, even if the State Bank of India carries on business through various branches within the jurisdiction of Zila Parishad, Gorakhpur, the Zila Parishad has jurisdiction to impose a tax on the totality of the circumstance of the State Bank of India, of course, subject to the maximum of the limit prescribed by the rules. It cannot separately tax various branches of the State Bank of India which branches cannot be considered to be persons within the meaning of Section 121 of the Act. 7. In view of the aforesaid discussion, we are of the opinion that the Respondents has no jurisdiction to assess and recover circumstance and property tax as against various branches of the State Bank of India located within its territorial jurisdiction. The Petitioner, however, does not object to the payment of circumstance and property tax for various years calculated at the rate of Rs. 2,000/-per year in respect of totality of its circumstances and property, viewed in the light of the business conducted by it through all its branches located within the jurisdiction of Zila Parishad, Gorakhpur. 8. In the result, the petition succeeds and is allowed with costs. The Respondents are directed not to recover circumstance and property tax for various years in respect of the business carried on by the State Bank of India through each of its branches separately. The Zila Parishad will, however, be free to recover circumstance and property tax from the State Bank of India for the various assessment years at the rate of Rs. 2,000/- per annum. The interim order passed in this case is vacated.