ITAT explain difference between Corporation by and under an Act while considering TDS on Interest to Noida

Facts of the CAse The assessee, a Branch of Canara Bank, made interest payment of Rs.201,000,000/- to New Okhla Industrial Development Authority (herewith ‘NOIDA’), a creation of the UP Industrial Area Development Act, 1976, without withholding any tax at source. NOIDA claimed before the assessee bank that it was a local authority and, hence, its income was exempt from tax and, as such, no withholding of tax at source was required. The matter was taken up to Hon’ble Allahabad High Court by way of writ petitions as many banks were against the NOIDA’s claim of its eligibility for exempti...