Nil TDS certificate issued by AO U/s. 195(2) in contravention of provisions not binding on revenue

ISSUE NO.2: Whether the issue of shares by the Assessee on 30.3.2004 and 30.9.2004 can be said to be covered by the order of non- deduction of tax at source issued by the AO in his order dated 22.2.2005 and therefore in respect of issue of shares on the above two dates the Assessee cannot be proceeded against u/s. 201(1) & 201(1A) of the Act? It was contended by the ld. counsel for the assessee that since the AO has passed an order u/s. 195(2) of the Act allowing the assessee to issue shares without tax deduction at source, the issue of shares made by the assessee on 30.03.2004 and 30.09.2...