The assessee-bank had various fixed deposits of the Agra Development Authority, a statutory body constituted under the provisions of the Uttar Pradesh Urban Planning and Development Act, 1973, under different identifications for many years. For the assessment years 2012-13 and 2013-14, penalty under section 271C of the Income-tax Act, 1961 was imposed on the bank for failure to deduct tax at source on payments of interest on these deposits to the Authority. The Tribunal and the High Court affirmed these orders. On appeal to the Supreme Court, allowing the appeals, that the Agra Development Authority had been constituted under the Uttar Pradesh Urban Planning and Development Act, 1973 and was covered by notification dated October 22, 1970 (Notification No. S. O. 3489 Dated October 22, 1970.) issued under section 194A(3)(iii)(f) of the Income-tax Act, 1961, notifying payments to “any corporation established by a Central, State or Provincial Act” to be exempted from the requirement of tax deduction at source. The orders levying penalty were liable to be set aside. (AY.2012-13, 2013-14)