Dismissing the appeal of the revenue the Court held that the assessee merely performed the statutory functions under the 2005 Act, and collected the tax amount for and on behalf of the State and transferred such collection to the Government Treasury. Even if the tax collection remained temporarily parked with the assessee for some time, it could not be treated as “income” generated by the assessee as the amount did not belong to it. Hence, it did not partake of the character of “profit or gain” earned by the assessee. The non-registration of the assessee under section 12AA of the Act was inconsequential. (AY.2007-08 to 2011-12, 2013-14)