Assessee, a statutory authority, entered into a contract with a foreign company for development of highways. Assessee made payments to deductee after obtaining certificates under Section 197(1) prescribing marginal TDS rates for assessment years 2008-09 and 2009-10. Assessing Officer held that the certificate issued on 30-06-2008 would apply only prospectively and treated the assessee as in default under section 201 for payments made prior to that date (payments made between 10-04-2008 and 24-06-2008) and levied interest under section 201(1A). Court held that every provision of the Income-tax Act is liable to be applied for a particular assessment year, and even tax liabilities are fixed on the assessee for the entire assessment year. Therefore, certificate issued under Section 197 for a particular financial year would operate for the entire corresponding assessment year. Therefore, the assessee could not be treated as an assessee in default under Section 201, nor made liable to interest under Section 201(1A) because the assessee had a certificate under Section 197 for the entire assessment year.   (AY. 2008-09 to 2009-10)