IT : Decision which is quasi-judicial in nature, has to be taken by Assessing Officer under section 197(1) on objective criteria and be based on relevant material provided by applicant and available with department - It must be supported by reasons available on file which conform to requirement of section 197 of Act read with Rule 28AA of Rules - Those reasons must be communicated to applicant - It cannot be taken, on dictation of an officer superior to Assessing Officer
from www.taxmann.com Latest Case Laws https://www.taxmann.com/topstories/101010000000189618/‘lower-withholding-certificate’-can’t-be-issued-on-dictates-of-an-officer-superior-to-ao-delhi-hc.aspx
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