1. These are eight appeals and eight cross objections by department and assessee relating to assessment years 2004-405 to 2011-12 respectively.

2. Identical ground in all the appeals of the department are as under :-

"On the facts and in the circumstances of the case the ld. CIT (Appeals) has erred in deleting the demand raised under section 201(1)/201(1A) of the I.T. Act by the A.O. on account non-deduction of tax source by the assessee on payment of interest to the Rajasthan Rural Development Agency as the said agency is not covered under circular No. 4/2002 in respect of Boards or Bodies whose income is unconditionally exempt under section 10 of the IT Act, 1961, as claimed by the assessee before the ld. CIT (A)."

3. In the present cases, proceedings under section 201(1) and 201(1A) for assessment years 2004-05 to 2011-12 for non deduction of TDS on the interest paid by the assessee bank to Rajasthan Rural Road Development Agency (RRRDA), a body formed by the State Government, was initiated.

4. On survey by department, it was revealed that Rajasthan Rural Road Development Agency, a nodal agency was formed as a Society by the State Government. The Ministry of Rural Development,