By the Court.—Heard Sri Dhruv Agarwal for petitioner, Sri Krishna Agrawal for respondent No. 1, Sri Manish Goyal for respondent Nos. 2 and 3, and Sri Shambhu Chopra for respondent No. 5.

2. In both these writ petitions, dispute relates to validity of orders passed by Income Tax Officer (TDS and Survey) (hereinafter referred to as “ITO (TDS)”) in purported exercise of powers under Section 201 (1) of Income Tax Act, 1961 (hereinafter referred to as “Act, 1961”) demanding amount of tax deductible at source (hereinafter referred to as “TDS”) and interest under Section 201 (1A) in respect to Financial Year 2000-01 (Assessment Year 2001-02) and Financial Year 2001-02 (Assessment Year 2002-03).

3. The facts in brief giving rise to present dispute are as under.

4. Petitioner - Ghaziabad Development Authority (hereinafter referred to as “GDA”) is a Statutory body constituted under provisions of U.P. Urban Planning and Development Act, 1973 (hereinafter referred to as “Act, 1973”) for the purpose of undertaking planned development within area of Ghaziabad and others as notified