Case Law Analysis
|Delhi High Court
Section 197 Income Tax Act | Arbitrary Rejection of NIL Withholding Certificate Violates Rule 28AA & Legitimate Expectation Doctrine : Delhi HC
Delhi High Court quashes the rejection of a NIL TDS certificate under Section 197, ruling that administrative authorities must apply Rule 28AA and consider past consistent grants, as arbitrary denial breaches legitimate expectations. The judgment mandates evaluation of pending demands rather than mere citation, impacting taxpayers seeking lower withholding rates.