Commissioner (Appeals) passed order that NOIDA being an industrial development authority, was eligible to benefit of section 194A(3)(iii)(f).  Accordingly, he opined that petitioner-bank was entitled in law not to make deduction of TDS on interest payment made to NOIDA. That issue was specifically carried in appeal by Revenue to Tribunal and Tribunal, after specifically examining issue, held that assessee was not liable under section 201(1) and 201(1A) of the Act. Revenue’s appeals before High Court and Supreme Court were dismissed. CIT(A) thereafter passed rectification order treating the asssessee in default. On writ allowing the petition the Court held that  order of Commissioner (Appeals) stood merged with order of Tribunal, and further with subsequent orders of High Court and Supreme Court; hence, there did not remain or survive any jurisdiction with Commissioner to seek any rectification or correction in his earlier order.