Binding High Court directions cannot be ignored for a nil-rate withholding certificate when no stay has been obtained.

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....A High Court direction in the taxpayer's own case for the same financial year remained binding, and the competent authority could not refuse a nil-rate tax withholding certificate merely because the Department was considering an SLP, especially where no stay had been obtained. The rejection of the application under section 197 was therefore unsustainable. The impugned order was set aside, and the authority was directed to issue the nil-rate withholding certificate within three days for the relevant financial year.....