Amount remained in hands of assessee till date of assessments, Assessing Officer treated said amount as income. On appeal High court held that liability to pay and corresponding authority of State to collect tax (flowing from a Statute) is essentially in realm of rights of sovereign, whereas obligation of agent to account for and pay amounts collected by him on behalf of principal is purely fiduciary hence, section 43B could not be invoked for making assessment of liability of assessee-corporation under Act with regard to amount collected by it as an agent of State towards tax payable by consumers of electricity to State.Followed   Kerala State Electricity Board v. Dy.CIT (2010) 329 ITR 91 /  (2011) 196 taxman 1 (Ker)(HC)  (AY. 2006-07 to 2009-10)