TMI Blog1999 (8) TMI 10X X X X Extracts X X X X X X X X Extracts X X X X ..... rd both the sides on the question of interim relief. The grievance of the petitioner is that there is no time-limit for making an application for a certificate under section 197 nor is there any time-limit for issuance of such certificate, and even though till now, in numerous cases, certificates have been issued under section 197 even where the applications are presented later than giving of cred ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of the Assessing Officer in this regard. It appears that the Central Board of Direct Taxes in this regard wrote a letter dated October 9, 1997, a copy of which is at annexure K to the petition, to the petitioner reiterating that since the certificate was applied for after the amount of interest was credited, the question of issuing certificate for non-deduction of tax at source under section ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ne important aspect that strikes is that, since so far certificates have been issued in almost all cases as stated by the petitioner's counsel and not seriously controverted by the other side, there would be a class of people, who expecting similar treatment may have applied for the certificate after the credit of interest is given, expecting that the certificate will be issued in their case also ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion whatever decision it may take before the next date of hearing. ORDER August 3, 1999.---Learned advocate, Mr. J. P. Shah, states that in view of the interim orders passed by this court, the petitioner has been given the benefits, and, therefore, this petition has become infructuous. This petition, therefore stands disposed of accordingly. Rule is discharged. No order as to costs. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
