Allowing the petition the Court held that since the authorities were required to pass an order under section 197 either rejecting the application for such certificate or allowing such application resulting in issuance of certificates which may be at rates higher than nil as sought for by the assessee, such an order must be supported by reasons. Not only that, a copy of such an order had to be furnished to the assessee so that it could be challenged under section 264 if aggrieved. Not passing an order to that effect or keeping such an order in file without communication would vitiate the certificates. The reasons for not granting nil rate certificates to the assessee were not known. The contemporaneous order required to be passed under section 197 was also not available. The order was set aside and the certificates were quashed. The matter was remanded to the Dy.CIT (TDS) for passing fresh order and issuing consequential certificates under section 197 complying with the requirements of rule 28AA. Matter remanded. (AY.2021-22)