Income Tax, Tezpur Circle and others, (2007) 290 ITR 139 . In the said decision, the Arunachal Pradesh Forest Corporation Limited has claimed the benefit under Section 10(26B) though not having been established by specifically stating that it is for the benefit of the Scheduled Tribes. While making a consideration of that aspect, this Court had taken note of the fact that the Corporation had been set up to promote the development of the local population and on taking note that admittedly the tribal population constitutes the bulk of entire population, the benefit as claimed is held admissible. This is distinguishable from the facts of that case and as arising in the instant case. In the said case the Corporation had been set up for the entire population of the State and, in that light, the situation of the overwhelming tribal population was taken note as such population would be benefitted. However, in the instant facts as already noted, the appellant Corporation was set up for the benefit of police personnel in Arunachal Pradesh, in the name and style of Arunachal Police Housing and Welfare Corporation Limited, for the purpose of formulating and executing housing scheme for the benefit and welfare of the employees of the Police Department, Government of Arunachal Pradesh. In that view, it is not set up for the purpose of the general population, but limited to a particular class of employees of the Government of Arunachal Pradesh and in such circumstance, all persons of the Police Department cannot be considered as belonging to Scheduled Tribe, even if the reservation policy for recruitment is kept in view. Therefore, in such circumstance, the benefit of the provision, as referred to, would not be applicable to the present case.
