Dismissing the appeal of the revenue the Court held that  the Gujarat State Road Development Corporation was a wholly Government owned company incorporated pursuant to the State Government’s resolution dated February 28, 1999. The members and the board of directors and the memorandum of association would show that the Government enjoyed total control over the Corporation. There was a requirement of four laning of road near GSFC junction, Vadodara. A request for this purpose was made by the Gujarat Industrial Development Board. For the road widening, the Government of Gujarat, Road and Building Development, under its resolution dated August 1, 2002 allotted the land for construction of the road on build, operate and transfer basis. The concession agreement which the Gujarat State Road Development Corporation entered into with the assessee was approved by the State Government in its meeting dated October 24, 2000. The Government of Gujarat passed an order dated March 7, 2003 permitting the assessee to collect toll fee at prescribed rates. The Gujarat State Road Development Corporation was a nodal agency constituted by the State Government for the purpose of executing road development projects through private participation would be a Government agency as defined in section 2(e) of the Gujarat Infrastructure Development Act, 1999. The assessee was entitled to special deduction under section 80IA . ( AY.2010-11)