The assessee is  a statutory authority created under the Karnataka Urban Development Authorities Act, 1987 . The registration was denied  which was affirmed by the Appellate Tribunal. On Appeal the Court held that  the purpose and intent of creation of the authority was to establish urban areas in Belgaum in a planned manner. The assessee being a statutory authority was under the control of the State Government, which had the power to issue directions to the Authority. The directions were necessary or expedient for carrying out the purposes of the Act and it would be the duty of the assessee to comply with such directions. Even the utilization of funds by the assessee was fully controlled by periodical instructions issued by the Government. The funds standing in the name of the assessee were under the absolute control of the Government as the assessee functioned in a fiduciary capacity. The assessee is  a charitable institution entitled to registration under section 12A . Rule 17A have to be complied with.