These connected cases are filed by the Welfare Fund Boards, constituted under various State Legislations providing for payment of welfare fund to building construction workers, toddy workers, abkari workers, tailoring workers etc., for a declaration that petitioners are entitled to receive interest payment from Banks, Treasuries etc. without deduction of income tax at source under Section 194A

(1) of the Income Tax Act.

2. I have heard learned counsel appearing for petitioners and learned Standing Counsel appearing for respondents.

3. The claim of the petitioners is that petitioners are entitled to receive payment of interest without deduction of tax at source by virtue of their inclusion under Clause 22 of Notification No.SO 3489 dated 22-10-1970 issued by the Central Government under Section 194A(3)(f) of the Act. Learned standing counsel on the other hand contended that petitioners are not covered under Clause 22 of the Notification above referred and therefore payment of interest has to be made to petitioners only after deduction of tax at source under Section 194A(1) of the Act. Clause 22 of the notification above referred is extracted hereunder for easy reference:

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