V. Ramasubramanian, J.

1. All these appeals are by the branch offices of one assessee, namely, The Coimbatore District Central Co-operative Bank Limited, filed under Section 260A of the Income Tax Act, 1961. The assessee has come up with the above appeals, raising the following substantial question of law:-

"Whether a co-operative society, carrying on banking business with the approval of the Reserve Bank of India, is liable to deduct tax under Section 194A of the Income Tax Act, 1961 on the interest paid to its members?"

2. We are of the considered view that in addition to the above substantial question of law, one more substantial question of law also arises for consideration, namely,

"Whether there is any distinction between a co-operative bank and a co-operative society carrying on banking business and if so, under which category the appellant would fall?"

3. Heard Mr. K. Ravi, learned counsel for the appellants and Mr. J. Narayanasamy, learned senior standing counsel for the respondent.

Brief Facts:-

4. The facts in brief out of which the above appeals arise are as follows:-

"(a) The appellant is registered as a co-operative society, in terms of the provisions of the Tamil N