Assessee by way of instant writ petition pleaded before Court to direct CBDT to issue direction that sale of shrink-wrapped-packaged software on CD/DVD was sale of goods and was not subjected to tax deduction at source under section 194J/194C by its customers. In terms of section 119(1), there is no duty cast upon CBDT to issue clarification and decide matters which would be essentially in realm of adjudication before revenue authorities. Court also held that there was no legal right to assessee and/or its customers to compel CBDT to give ruling on issue of tax deduction at source, therefore, instant writ was to be dismissed.