Co-operative society is not an "authority" under section 10(29), so exemption for its entire income fails.

A co-operative society registered under the Co-operative Societies Act, 1912 is not an "authority" within section 10(29) of the Income-tax Act, 1961 because that Act facilitates the formation of societies and does not itself constitute an authority. The separate legislative treatment of co-operative societies under section 80P further shows that such societies were not intended to fall within the exemption for authorities under section 10(29). The society therefore cannot claim exemption of its entire income under that provision.

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Issues: Whether a co-operative society registered under the Co-operative Societies Act, 1912 is an "authority" within the meaning of section 10(29) of the Income-tax Act, 1961 and entitled to exemption of its entire income.

Analysis: Section 10(29) of the Income-tax Act, 1961 applies to income of an "authority" constituted under law. The Co-operative Societies Act, 1912 was enacted to facilitate the formation of co-operative societies and not to create an authority. A co-operative society formed under that Act therefore does not answer the description of an authority. The separate treatment of co-operative societies in section 80P of the Income-tax Act, 1961 also indicates that the legislature did not intend such societies to fall within section 10(29).

Conclusion: The assessee-society is not an "authority" within the meaning of section 10(29) of the Income-tax Act, 1961, and the exemption claim fails.

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