1. All these appeals are filed by the Commissioner of Income Tax, Trichur against the order of the Income Tax Appellate Tribunal, Cochin Bench. I.T.A. Nos.16, 18, 19, 21 and 23 of 2001 arise out of a common order of the Tribunal in I.T.A. Nos.883, 884, 885/Coch/90, 7 & 8/Coch/91 and 271/Coch/91 in the case of Dhanalakshmi Bank, Thrissur. (I.T.A. No.11/01 filed against I.T.A. No.883/90 which was disposed of by the Tribunal by the common order is being dealt with separately since one more question is involved in the said appeal). I.T.A. No.83/02 arises out of the order of the Tribunal in I.T.A. No.79/94 in respect of the assessment year 1990-91 in the case of South Indian Bank Ltd., Thrissur. Similarly I.T.A. Nos.127/01 and 135/01 arise out of the order of the Tribunal in I.T.A. Nos.295 & 296 of 1993 in respect of the assessment years 1988-89 and 1989-90 in the case of Catholic Syrian Bank Ltd., Thrissur. All these appeals are being disposed of by this judgment since the sole question that arises for consideration in all these cases is as to whether the Tribunal is right in law in holding that the rate of penal interest the assessee has to pay under the relevant banking l