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of Lower withholding certificate u/s 197 - requirement of reasoned order - the decision of the AO u/s 197(1) is quasi-judicial in nature, has to be taken on objective criteria and be based on relevant material provided by the applicant and available with the Department - It must be supported by reasons available on the file which conform to the requirement of Section 197 r.w. Rule 28 AA - reasons must be communicated to the applicant also
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