As per case facts, the Commissioner of Income Tax (TDS), Bhopal, challenged ITAT orders for assessment years 2008-09 and 2009-10. The respondent, National Highway Authority of India (NHAI), made payments ... to a contractor, deducting tax at marginal rates based on Section 197(1) orders. However, the Assessing Officer noticed payments were made without a valid lower deduction certificate in force, leading to a default assessment and interest levy. The AO and CIT argued that the Section 197 certificate applied prospectively from its issuance date, while the ITAT ruled that the deductor was not in default. The question arose whether the benefit of a Section 197 certificate applies from its issuance date or covers the entire assessment year, and if the assessee deductor could be held in default under Section 201(1) and 201(1A) for payments made before the certificate's issuance. Finally, the High Court dismissed the appeals, affirming the ITAT's decision. It held that Section 197 certificates are valid for the entire financial year. Thus, the assessee cannot be deemed in default for not deducting tax at source, and the deletion of interest levied under Section 201(1A) was justified as the certificate's effect covers the whole assessment year.