Allowing the appeal of the revenue the Court held that ; Urban improvement Trust constituted under Rajasthan Urban Improvement Act , 1959 is not local authority  , hence not entitle to exemption  .The High Court based its decision on the fact that functions carried out by the assessee are statutory functions and it is carrying on the functions for the benefit of the State Government for urban development. The said reasoning cannot lead to the conclusion that it is a Municipal Committee within the meaning of Section 10(20) Explanation Clause (iii). The High Court has not adverted to the relevant facts and circumstances and without considering the relevant aspects has arrived at erroneous conclusions. Judgments of the High Court are unsustainable.  The functional test” as laid down in UOI v. R.C. Jain, (1981) 2 SCC 308 is  not applicable after amendment of section 10 (20) of the Act by Finance Act , 2002 .(CA.NO. 10577   of 2018, dt. 12.10.2018) ( AY. 2003 -04 to 2009-10 )