upheld the fixation of tax on cinema shows, albeit the Calcutta Municipal Act, 1951 had failed to prescribe a limit to which tax could go. The majority in Liberty Cinema (supra) had referred to Pandit Banarsi Das (supra) and held that there is no in-principle distinction between delegation of power to fix rates of taxes to be charged on different classes of goods and power to fix rates simpliciter; if power to fix rates in some cases can be delegated then equally the power to fix rates generally can be delegated. The Court held that if the power to decide who is to pay the tax is not an essential part of legislation, neither would the power to decide the rate of tax be so. The Court thus held that fixation of tax rate was not unqualified as the legislature had stipulated the maximum rate. The guidance rule was held as satisfied. 31. We are of the opinion that the enactment of subordinate legislation for levying tax on interest free/concessional loans as a fringe benefit is within the