Judgment :- R. JAYASIMHA BABU, J. Counsel for the Revenue has placed before us the following two questions as reframed by him, which he submits are questions which require consideration by this court, "1. Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was right in deleting the additions of Rs. 19, 726 and Rs. 1, 01, 301 made to the chargeable interest as per the order of the Commissioner of Income-tax under section 19 of the Interest-tax Act, 1974 ? 2. Whether the Appellate Tribunal was right in holding that the transaction between the assessee and the Agricultural Development Refinance Corporation and the Industrial Development Bank of India and the transaction of lending of money by the assessee-bank to its constituents should be viewed as one integrated transaction and only the net interest accrued to the assessee should be brought to tax ?" As regards the first question, it is fairly submitted by learned counsel for the Revenue that in respect of the sum of Rs. 19, 726 the order of the Tribunal is in accordance with the law that has been declared in three decisions, viz., CIT v. State Bank of Indore, CIT v. Canara Bank and CIT v. Federal Bank Ltd. It is not the case of the Revenue that any of those decisions have been taken up in appeal to the Supreme Court or that in any other matter the ratio laid down in the aforementioned decisions has been reversed by the Supreme Court. In the circumstances, we deem it unnecessary to call for a reference merely for the purpose of reiterating the law which has been declared and also accepted by the Revenue. As regards the second question, the Tribunal has found that the transaction is an integrated one. The monies lent by the bank to its constituents being monies which originated from the Industrial Development Bank of India which in turn had been made available to the Agricultural Development Refinance Corporation on certain conditions for the purpose of making the monies available through banks. The interest has to be paid by the ultimate borrowers as also by the lending bank, as stipulated in the agreement. The interest has to be paid by the ultimate borrowers as also by the lending bank, as stipulated in the agreement. The assessee-bank has entered into an agreement with the A.D.R.C. and the I.D.B.I. in accordance with the agreement that was entered into between the Agricultural Development Refinance Corporation and the Industrial Development Bank of India. The transaction commencing from the IDBI to the ultimate borrower is in the circumstances an integrated transactionThe Tribunal has therefore in that background held that the interest received by the lending bank from the constituents for the monies lent by the bank from and out of the monies made available to it by the A.D.R.C. and the I.D.B.I. did not in its entirety accrue to the lending bank. It was in that sense the lending bank was functioning as an agent for that part of the interest that had to be paid to the A.D.R.C. and the I.D.B.I. and the sum of Rs. 1, 01, 301 referred to in the first question is the amount so paid. We, therefore, do not deem it necessary to call for a reference. Tax case petition is dismissed.