What is the criteria to quality an entity to be a Government / Governmental Authority / Local Authority / Government Entity ?
TRT-2026-897

Issue Favourable to Tax Payer ?:- yes

Held - We observe that there is no doubt that Forest (Conservation) Act, 1980 in the state of Uttarakhand is also implement and regulated by the Forest Department of State Government of Uttarakhand and the UK CAMPA is under the aegis of Forest Department of State Government of Uttarakhand, as they administer, manage and regulate the said act.

We also find that vide letter dated 08.08.2022, the applicant submitted sample demand letters ra.....

TRT-2026-899

Issue Favourable to Tax Payer ?:- yes

Held - In order to qualify as a governmental authority, such authority must be set up by an act of Parliament/State Legislature, should have 90% or more stake of government, and should carry out any function entrusted to a Municipality under article 243 W of the Constitution of India.

As already discussed, the UPJN is a body corporate formed by the State legislature under UPWSS Act enacted by the UP State Legislature. As such, the first .....

TRT-2026-915

Issue Favourable to Tax Payer ?:- yes

Held - Karnataka State Police Housing and Infrastructure Corporation Limited is a company of the Government of Karnataka incorporated under the companies Act 1956 and all the shares of the company are held by Government of Karnataka. In view of the definitions mentioned in the para 10 supra, Karnataka State Police Housing and Infrastructure Corporation Limited qualifies to be considered as a Government Entity.

Kudala Sangama Development .....

TRT-2026-917

Issue Favourable to Tax Payer ?:- no

Held - The applicant states that he has also entered into an agreement with Karnataka Housing Board for construction of Magadi Road Police Station at Govindarajanagar constituency, Bengaluru. Karnataka Housing Board is established under Karnataka Housing Board Act 1962.

The Karnataka Housing Board (referred as KHB) is established under Karnataka Housing Board Act 1962 and carries out function entrusted by the State Government. Hence the .....

TRT-2026-926

Issue Favourable to Tax Payer ?:- yes

Held - In the instant case, it is observed that the MoU was entered into between the Applicant and M/s SAIL for construction of Ispat Post Graduate Medical Institute and Super Specialty Hospital at Rourkela Steel Plant. Subsequently, the said work was entrusted to M/s URC Construction (P) Ltd (the sub contractor of the Applicant) for execution. AAR. Odisha vide Order dated 09.03.2021 held that M/s SAIL, Rourkela qualifies to be called and term.....

TRT-2026-873

Issue Favourable to Tax Payer ?:- yes

Held - We have examined the Government of Gujarat Resolution dated 20-2-99, placed before us by the applicant, whereby GSRDC was established with objective to undertake the development of bridges and roads. We find that Government of Gujarat has established GSRDC as its wholly owned company and entrusted it with the development of roads and bridges. Thus, we find that GSRDC satisfies the definition of Government Entity.

Further, as submi.....