Allowing the petition the Court held that , the petitioner was to provide amenities and facilities in industrial estate and in industrial area in the form of road, electricity, sewage etc. The assessee necessarily required money and funds, which were received from the State Government. Assessee, given the regulatory and administrative functions performed is required and charges fee, cost and consideration in the form of rent and transfer of rights in land, building and movable properties. Similarly payments had to be made for acquisition of land, creation and construction of infrastructure and even buildings. Carrying out and rendering the said activities was directly connected with the role and statutory mandate assigned to the assessee. It had not been asserted and alleged that these activities were or were undertaken on commercial lines and intent. Assessee did not earn profits or income from any other activity unconnected with their regulatory and administrative role. Income in the form of taxes, fee, service charges, rents and sale proceeds was intrinsically, immediately and fundamentally connected and forms part of the role, functions and duties of the assessee.  Accordingly the Court held that the petitioner is entitle exemption u/s 10(46 ) of the Act.