On writ the Court held that the Assessing Officer in his order that approval of higher authorities was taken on the online TRACES portal. Consequently, since the order was passed after an approval from the Commissioner, it could not be challenged by way of a revision petition before the Commissioner under section 264.   Notification No. 8 of 2018 dated December 31, 2018 issued by the Central Board of Direct Taxes mandates that the decision under section 197 with effect from December 31, 2018 has to be taken by the Commissioner, i. e., after a conscious application of mind. The assessee had no alternate remedy and so the writ petition was maintainable.  Court also held that the Assessing Officer cannot ignore the mandate of rule 28AA and proceed on any other basis as the Government is bound to follow the rules and standards it had itself set on pain of the action being invalidated. Consequently, the order was not valid and was liable to be quashed.