1999 (8) TMI 10

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.... K. ABICHANDANI J.---Rule. Matter to come up for final hearing on April 1, 1998. We have heard 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 be....

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....and, therefore, the Commissioner of Income-tax, regretted his inability to interfere with the action 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....

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.... and that the issuance of certificate after giving the credit of interest was not permissible, one 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 th....