S. Ravindra Bhat, J.

1. This common judgment will dispose of a batch of writ petitions. They were heard together as they involve identical questions of fact and law as to the correct interpretation of Section 194-I of the Income Tax Act [hereafter “the Act”].

2. The petitioners are engaged in developing, constructing and selling residential units, plots and flats. Each of them entered into a long-term 90 years lease with the Greater Noida Industrial Development Authority (GNOIDA) [hereafter referred to as “the authority” or “the lessor”], as the case may be, i.e. one of the respondents in all these writ proceedings, for development and sale of land in various housing colonies. In terms of the lease deed entered into with the lessor, the petitioner paid upfront consideration and the balance was payable in terms of annual installments according to the terms and conditions of the lease deed. Along with the lease premium, each lease deed contained stipulation that interest payments would also be made to the lessor/authority. These stipulations are part of the lease deed [Clause 1 of the lease in W.P.(C) 1214, 2649 of 2016 as well as W.P.(C) 8085/2014; W.P.(C) 7682/2015 and W.P.