2024 (8) TMI 826

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....er/s : Mr. Ajay Kumar Rastogi, Sr. Advocate, Ms. Smriti Singh, Advocate For the Respondent/s : Mrs. Archana Sinha, Sr. SC, Income Tax Dept. ORAL JUDGMENT PER: HONOURABLE THE CHIEF JUSTICE The writ petition is filed against Annexures-P/1 and P/2 orders, which resulted in rejection of applications filed under Section 197 of the Income Tax Act, 1961. The orders are dated 14.05.2023 and 30....

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....wer to satisfy himself that the total income of the recipient justifies the deduction of Income Tax at any lower rates or at a NIL rate. Hence, a demand pending against the assessee would not clothe the Assessing Officer with the power to summarily reject an application under Section 197. The satisfaction to be recorded under Section 197 is clearly with respect to the total income of the recipient....