Certificate issued U/s./ 195(2) was not withdrawn so assessee was not required to deduct TDS and could not be treated as assessee in default

The court has rested its decision, quite rightly so, on the only ground- though not specifically addressed- that the certificate granted U/S 195(2) was in force; hence there was no case for the Revenue to treat the Respondent as an assessee-in-default. Consequently, the court has refused to give its opinion on the two questions turning on ‘merits’ actually referred.
The court seems to have tacitly taken a very liberal / mild view of the whole matter; thereby, obviating the scope for multiplicity of proceedings. In that, it has refrained from taking a serious or adverse view of the abject failure on the part of the Revenue in giving any thought to and seeking to raise what really was a proper, or primarily essential question, if not the only one, to be framed for reference to court.
Of course, if it were to have been the only or primary question raised then, there was every possibility of a reference to court having been refused. For, in one’s strong conviction, as is supported by the court’s judgment itself, the proper question, perhaps the solitary question clinching the dispute that could have been raised is that turning on section 195. The provision of law being amply clear, a view could have been taken that the dispute involved no ‘referable’ question of law in its profound sense.
Further, on the flip side, a grave doubt that keeps haunting one’s mind is this:- Would not the court proceedings have possibly been avoided /averted had, even at the stage of second appeal, the decision been handed out on the same exclusive ground as has since been done by the court.