TMI Blog2014 (12) TMI 854X X X X Extracts X X X X X X X X Extracts X X X X ..... ed at the rate of 5.5 per cent, which, although is a lower rate than prescribed, is not the Nil rate desired by the assessee – revenue seems to have added up the tax liabilities of the previous three years, whereas, in fact, according to the assessee, two out of the three years’ liability has already been deleted in appeal and in respect of the third year also an appeal is pending on the same grou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... receipts are concerned should be Nil, whereas, the Assessing Officer has directed that TDS be deducted at the rate of 5.5 per cent, which, although is a lower rate than prescribed, is not the Nil rate desired by the petitioner. There is some dispute with regard to the existing tax liabilities of the petitioner. The revenue seems to have added up the tax liabilities of the previous three years, whe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... quested by the learned counsel for the petitioner that whenever the application under Section 197 is made, the same should be disposed of expeditiously. We are of the view that if the petitioner moves the application in the first week of financial year, the same ought to be disposed of within a reasonable period of time which we think in the case of TDS Certificates under Section 197 should be not ..... X X X X Extracts X X X X X X X X Extracts X X X X
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