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 Al

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