Dismissing the appeal of the revenue the Court held that the  assessee was a statutory authority created under the Karnataka Urban Development Authorities Act, 1987. The purpose and intent of creation of the assessee was to establish urban areas in Hubli-Dharwad 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 in terms of section 65 of the Act. 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. Accordingly the assessee is entitled to continue the certificate of registration under S. 12A of the Act.