JUDGMENT :

ASHOK BHUSHAN, J.

Leave granted.

2. These appeals question the Division Bench judgment dated 04.04.2016 of the Allahabad High Court, by which judgment Income Tax Appeals filed by the Revenue has been dismissed affirming the order of the Income Tax Appellate Tribunal. The common questions of facts and law are involved in these appeals and it is sufficient to refer the facts and pleadings in Civil Appeal No.... 2018 arising out of SLP(C) 3168 of 2017, Commissioner of Income Tax(TDS), Kanpur and Anr. vs. Canara Bank wherein the judgment of the High Court dated 04.04.2016 in ITA No. 64 of 2016 has been questioned.

3. The New Okhla Industrial Development Authority (NOIDA), hereinafter referred to as “Authority” has been constituted by Notification dated 17.04.1976 issued under Section 3 of the Uttar Pradesh Industrial Area Development Act, 1976 hereinafter referred to as “1976 Act”. The Canara Bank, respondent No. 3 is the banker of the Authority. The respondent Bank made a payment of Rupees Twenty Crores Ten Lakhs as interest to Authority in form of FDs/Deposits for the fina