Assessee-development authority was constituted under U.P Urban, Planning and Development Act, 1973.Assessee collected fees and maintained an infrastructure fund as per directions of State Government out of which infrastructure related expenses were incurred. Assessee claimed that State Government had a overriding title on these receipts and they did not form part of its income.  Assessing Officer allowed infrastructure expenses but rejected claim of assessee with respect to diversion of receipts by overriding title and made addition with respect to balance infrastructure funds in hands of assessee. Order was affirmed by CIT(A) and Tribunal. On appeal the High Court held that assessee being a separate legal entity with its own assets and liabilities, would be distinct from State Government, thus, fees collected for infrastructure development would be treated as income of assessee and would be liable to be taxed in hands of assessee. (AY.  2006-07, 2007-08)