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2018 (10) TMI 874 - SC - Income TaxScope of Exemption u/s 10(20) - Municipal Committee within the meaning of Explanation to Section 10(20) - Urban Improvement Trust constituted under the Rajasthan Urban Improvement Act, 1959 - local authority within the meaning of Explanation to Section 10(20) - Held that:- The Municipal Board, Kota performs its functions, in areas where Municipal Board still exists. There is no reason to accept that Urban Improvement Trust is a Municipal Committee within the meaning of Section 10(20) Explanation Clause (iii). Coming back to Section 105, which provides for ultimate dissolution of Trust and transfer of its assets and liabilities to the Municipal Board, this provision does not in any manner improve the case of the assessee. When the Trust is dissolved or at dissolution, properties and funds and dues vested in or realisable by the Trust shall vest in and be realisable by the Municipal Board, which is a provision for different purpose and object. The above provision does not support the contention that Improvement Trust is a Municipal Committee as referred to in Clause (iii) of Explanation to Section 10(20). We, thus, are of the view that Scheme of the Rajasthan Urban Improvement Act, 1959 does not permit acceptance of the contention of the appellant assessee that Urban Improvement Trust is a Municipal Committee within the meaning of Section 10(20) Explanation (iii). The purpose and object for expression “Municipal Committee” used in Section 10(20) Explanation (iii) has been explained, as already noticed above, by this Court’s judgment in Agricultural Produce Market Committee Narela, Delhi [2008 (8) TMI 8 - SUPREME COURT].
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