Section 197 of the Income Tax Act, 1961 — TDS — It is the power and duty of the AO to decide applications under section 197(1), the Court would have ordinarily requested the AO to reconsider the issue and take a final decision without being guided or governed by any outside influence. For grant of certificate under section 197, satisfaction of AO and not higher authorities is necessary; in the peculiar facts and available time schedule for TDS and filing of return by assessee,  instead of demanding the matter to AO for reconsideration, the petition is dismissed — OPJ Trading P. Ltd. vs. Income Tax Officer [2018] 305 CTR (Gujarat) 413