Judgment :-

Heard learned counsel on both sides.

Appellant-Corporation [Assessee] was initially constituted as `Central Text Book Committee, which was attached to the office of the Director of Public Instruction. In 1950, the name was changed to `Assam Text Book Committee with ten members nominated by the State Government. In the year 1968, the Government re-constituted the said Committee as `Board of Text Book Production and Research. The said Board was converted into Corporation in 1972 and the name was changed to `Assam State Text Book Production and Publication Corporation Limited vide Notification dated 26th July, 1972 [for short, "the Corporation"]. All the assets of the said Board stood transferred to the Corporation with effect from 1st July, 1972. The Corporation had paid-up share capital of Rupees one crore and the break-up of the share holding was as follows:

NAME SHARES FACE VALUE

1. Governor of Assam, 9998 nos. Rs.99,98,000/- represented by the Secretary, Education

Department, Govt. of Assam

2. Financial Commissioner & 1 nos. Rs.1,000/- Secretary, Finance Department, Govt. of Assam

3. The Chairman, Board of 1 nos. Rs.1,000/- Secondary Education, Assam

As can be seen fro