ANDHRA PRADESH STATE ROAD TRANSPORTCORPORATION vs THE INCOME-TAX OFFICER AND ANR.

The Supreme Court held that the income of a State Road Transport Corporation is not exempt from income tax under Article 289 of the Constitution. The Court clarified that the Corporation operates with a distinct legal personality separate from the State, and thus its income cannot be considered as income of the State under clauses (1) or (2) of Article 289. The appeal against the High Court's dismissal of the writ petitions challenging the assessment orders was dismissed, affirming the tax liability of the Corporation under Section 22 of the Income-tax Act, 1922.