Dismissing the petition the court held that ;the first proviso to sub-section (1A) of S.230 of the  Act,  makes it clear that no person who is domiciled in India and in respect of whom circumstances exist, which in the opinion of the Income-tax authority render it necessary for such person to obtain a certificate under the section, shall leave the country unless he obtains a certificate from the Income-tax authority stating that he has no liabilities under the Act or that satisfactory arrangements have been made for discharging the liability under the Act.On facts the liability of the assessee was more than Rs. 400 crores. In the circumstances, the second respondent could not be found fault with for having insisted on a tax clearance certificate for the assessee to leave the country under the first proviso to sub-section (1A) of S.230.  ( AY. 2009-10- 2015-16 )