Order u/s 197 was quasi-judicial must be supported by valid & cogent reasoning

Bently Nevada LIC Vs ITO (Delhi High Court) Conclusion: The withholding certificate which directed TDS to be deducted at 5% on the payments made by the Indian entities to assessee-overseas company was unsustainable in law, inasmuch as there was arbitrariness and non-application of mind at various levels which vitiated the certificate. An order u/s 197 was quasi-judicial & must be supported by valid & cogent reasoning and it had to be based on objective criteria and relevant material. Thus, once again application made by assessee for issuance of a lower withholding certificate under Sec...