The assessee is an advertising and media agency, engaged in the business of advertising by creative and production work, media planning and incidental activities.  The assessee deducted the tax as per S.194C of the Act. According to the revenue tax should have been deducted as per S.194J of the Act as the rate applicable to professional or technical services. The Income-tax Officer (TDS) passed orders under section 201(1)/(1A) and held that the assessee had short tax deducted/not deducted tax at source to the tune of Rs. 91.10 crores during the assessment years. On a writ petition to quash the order the Court held that the orders could not survive the test of following the principles of natural justice. The Income-tax Officer (TDS) had collected extensive material, which was attributable to his own research, but never put such material to the assessee for its comments and most importantly his entire orders were founded on such research material. The orders were not valid. Accordingly the order was quashed.  (AY. 2017-2018) (WP No. 1719 of 2019 dt 29-07 -2019)