The Tribunal held that the STT is collected through a member broker under a particular client code. The client code is provided by the brokers and not by the stock exchange. Responsibility of the stock exchange is to ensure firstly that STT is collected as per s. 98, secondly, it has been determined in accordance with s. 99  read with r. 3 and Explanation thereto, and lastly, such STT collected from the purchaser or seller is credited to the Central Government as provided  under s 100 Tribunal further held that the stock exchange can only ensure determination of the value of taxable securities transaction purchased and provided sold through a client code at the prescribed rate. However, there is no mechanism provided enabling the stock exchange to collect STT beyond the client code. If a broker had not taken any separate client code then the stock exchange cannot be held responsible. Such failure could not be ascribed to the stock exchange because the client codes were not provided by the stock exchange but by the member brokers. Dismissing the appeal of the revenue the Court held that  under the statute stock exchange was not liable for any alleged short deduction of STT and therefore, no fault can be prescribed to the stock exchange and to hold the stock exchange to be in default for short collection of STT. (FY. 2005-06)