Certificate U/s. 197(1) for lower deduction cannot have retrospective effect

HIGH COURT OF GUJARAT Essar Oil Ltd. Versus Income-tax Officer  TAX APPEAL NO. 33 OF 2000 SEPTEMBER 3, 2012 JUDGMENT Ms. Sonia Gokani, J. The appellant, in the present Tax Appeal, has challenged the Order of the Income Tax Appellate Tribunal, Rajkot Bench, Rajkot [“Tribunal” for short] dated 28th February 2000 passed in ITA No. 193/Rjt/1999 for A.Y 1998-99. This Court, while admitting the appeal, has framed following question as substantial question of law : “Whether the appellant was liable to pay the amount of Rs. 77,78,973/= as a defaulter under Section 2...