JUDGMENT

Thomas, J.-The question raised, in its broad parameters, is whether industrial development could be enveloped within the expression "planning, development or improvement of cities, towns and villages or for both" in Section 10(20A) of the Income-tax Act, (for short the I.T. Act ).

2. Appellant, Gujarat Industrial Development Corporation, (for short the Corporation ) claimed exemption from taxation under the I.T. Act on two alternative premises, one under Article 289 (1) of the Constitution and the other under clause (20A) of Section 10 of the I.T. Act. A Division Bench of High Court of Gujarat disallowed the claim under both. Hence the Corporation has filed this appeal by special leave.

3. Corporation has been created under the Gujarat Industrial Development Act, 1962, (for short the Gujarat Act ) with the right to hold properties and the right to sue and be sued in its own name. The Income-tax Officer concerned repelled the claim of the Corporation for exemption from tax on both grounds, but the Appellate Assistant Commissioner (AAC), on appeal, upheld their claim on both counts. When the Revenue challenged the said decision in second appeal the Income Tax Appellate Tribu