Per Bench - These appeals by an assessee is arising out of the common order of the CIT(A)-IV Bangalore dated 12-9-2000 against an order passed under section 201(1) and section 201(1A). Since common issues are involved therein all these three appeals are disposed by a consolidated order.

2. Though the assessee has raised as many as 20 grounds and various sub-grounds within the grounds, the only issue to be decided in this appeal is whether the assessee is liable to be treated as an assessee in default under section 201 of the Income-tax Act (hereinafter called Act) for failure to deduct tax as required under section 192 of the Act in respect of benefit, if any, accruing to its employees in respect of issue of shares under its Employees Stock Option Plan (ESOP) and consequently whether assessee is liable for payment of interest under section 201(1A) of the Act.

3. Infosys Technologies Ltd. is a public limited company in the Information Technology Industry. It has formulated an Employees Stock Option Plan (ESOP). A trust was set up by the Infosys Technologies Ltd. The Trust was allotted warrants of Re. 1 each, each warrant entitling the holder thereby to apply for and be allotted o