Allowing the petition the Court held that  the very foundation for the rejection of application filed by the assessee under section 197 seeking a certificate for withholding tax at a low tax rate on the ground that there existed huge outstanding demand on their internal portal was self-contradictory. The Deputy Commissioner (TDS) had noted in his order the observation of the Assessing Officer that a number of rectification applications of the assessee were pending and once they were decided, the demand against the assessee was likely to be reduced to nil. Accordingly, the order was set aside  and directed  to decide the rectification applications filed by the assessee in accordance with law and any refunds under section 237 due and payable were to be refunded to the assessee.(AY.2008-09 to 2014-15, 2016-17 to 2018-19)