dissenting.
In order to understand the majority’s error it is necessary to understand the majority’s reasoning, which is: Counties are not authorized by either Code Ann. §§ 2-6202 or 2-6102 to tax for the purpose of sharing the revenue with cities; although the state is authorized by Code Ann. § 2-4704 to share state revenue with cities, the state is not authorized to delegate its tax power derived from Code Ann. § 2-4704 to counties; the state is not authorized by Code Ann. § 2-4701 to tax for the purpose of sharing the revenue with cities; the state cannot do indi*368rectly what it cannot do directly; hence the state cannot authorize counties to tax for the purpose of sharing the revenue with cities.
The majority has gone ’round the mulberry bush without ever really focusing on the central object — the bush itself, which is Code Ann. § 2-6201 as augmented by § 2-6202.
Code Ann. § 2-6201 provides: "The General Assembly may authorize any county to exercise the power of taxation for any public purpose as authorized by general law or by this Constitution. . . .” After lengthy analysis the majority conclude that the General Assembly may authorize counties to tax for any public purpose authorized by the Constitution (that’s what § 2-6201 succinctly says), but that the General Assembly cannot authorize counties to tax for public purposes authorized by general law unless also authorized by the Constitution. That is not what § 2-6201 says. By circumlocution the majority has obscured the critical words "by general law or.” Code Ann. § 2-6201 is self-contained authority for the General Assembly to "authorize any county to exercise the power of taxation for any public purpose authorized by general law. . .”
Moreover, Code § 2-6202 authorizes counties to tax for 14 specified purposes, plus such other powers, authority and purposes as may be conferred by the General Assembly. The majority treat Code Ann. §§ 2-6201 and 2-6202 as if they were adopted as part of and in the spirit of the Constitution of 1877. The majority fail to recognize that these provisions were adopted in 1966 (Ga. L. 1966, p. 1066).
We have here a continuation of that overly strict constructionalism resulting in constitutional amendments upon constitutional amendments for which this court is famous. Here however the majority goes around the mulberry bush out of choice rather than constitutional necessity. I would not erect roadblocks in the General Assembly’s search for tax relief where the Constitution does not require it.
I therefore dissent as to Division 1 of the majority opinion. Being unable to prevail on that issue, however, I must agree with Division 2 of the majority opinion. I *369therefore concur in the judgment.