Section 197 certificates must be preceded by an order

Tata Teleservices (Maharashtra) Ltd. Vs DCIT (Bombay High Court) Before issuance of certificates under section 197 of the Act, the same must be preceded by an order. That order must disclose reasons and is an order passed in exercise of quasi-judicial powers. Such an order can be assailed in revision under section 264 of the Act. Therefore, an order under section 197 of the Act must not only contain reasons but the same has also to be provided to the assessee who seeks a certificate under section 197. Otherwise, how will such an assessee assail the order in revision under section 264? In the c...