Court held that an order u/s 197 is quasi-judicial & must be supported by valid & cogent reasoning. It has to be based on objective criteria and relevant material. On facts, there is arbitrariness and non-application of mind at various levels which vitiates the certificate. The reasons do not conform to the requirement of s. 197 r. w. Rule 28 AA. The settled legal position is that orders passed by a statutory authority under “dictation” of a superior officer or anyone else is bad in law.The Court directed  the AO for issuance of a lower withholding certificate under Section 197(1) of the Act afresh in accordance with law. ( W.P.(C) 7744/2019 and CM APPL. 32145/2019 (stay), dt. 29.07.2019)