Judgment :- RAMAPRASADA RAO J. The petitioner is the owner of a house and premises No. 28/5, Chamiers Road, Madras-28. On August 1, 1970, he entered into an agreement with Sri Annamalai Mudaliar, residing at No. 27, Padavatta Amman Koil Street, Madras-7, for the sale of the property for Rs. 60, 000. One of the terms of the agreement is that the petitioner should register the sale either in the name of Sri Annamalai Mudaliar or in the name of any one of his nominees, if the petitioner is asked to do. But, as the value of the property exceeds Rs. 50, 000 the petitioner is obliged in law to obtain a certificate under section 230A of the Income-tax Act, 1961Section 230A has obviously been incorporated in the Income-tax Act, 1961The learned counsel for the petitioner, however, is unable to substantiate and further his argument as to how and in what manner the items referred to above are violative of the sense, text and content of section 230A. As already stated, this section is primarily intended to be a safeguard against tax evasion, and it provides a double standard in that it requires not only a tax clearance certificate from the Income-tax Officer but it prescribes an interdict to the registering officer not to register any document of the type under consideration unless the Income-tax Officer certifies in the manner he is asked to do so. It is to be seen that, whilst applying his mind to an application for the issue of a tax clearance certificate under section 230A read with rule 44A of the Rules, the registering officer has to be satisfied not only on the question that the person concerned has either paid or made satisfactory provision for payment of all existing liabilities but also on the other question that the registration of the document will not prejudicially affect the recovery of any existing liability. These limbs of section 230A loom large in the instant case. One cannot comprehend as to how the Income-tax Officer can make a decision on the issues and subjectively satisfy himself that prejudices to the revenue will not occur, unless he has an opportunity to peruse the document which is obviously going to be the subject-matter of registration before the registering officer. One cannot comprehend as to how the Income-tax Officer can make a decision on the issues and subjectively satisfy himself that prejudices to the revenue will not occur, unless he has an opportunity to peruse the document which is obviously going to be the subject-matter of registration before the registering officer. If, therefore, the very criteria which is necessary for the Income-tax Officer to satisfy himself subjectively is relatable to the document which is also to be registered by the registering officer, then it appears to me that the production of the document in some shape or other is an absolute necessity before the officer could arrive at a decision. It is this document that is referred to in section 230A which purports to transfer, assign, limit or extinguish the right, title or interest of any person to or in any property (other than agricultural land) valued at more than Rs. 50, 000 and that is one of the documents which comes within the purview of clauses (a) to (e) of section 17 of the Indian Registration Act. Viewing the sense of the section from any angle, it appears to me that it is elementary that, before a certificate is issued by the Income-tax Officer, he should apprise himself of the contents of the document which is going to be the subject-matter of registration. If this is, therefore, the essence or meaning of section 230A, items Nos. 14 and 17 are merely some of the elements which are invariably recited in such documents. Item No. 14 speaks of name and address of the transferee. No document worth the name is complete without mentioning name and address of the transferee. As regards item No. 17, it is common knowledge that a completed document which purports to transfer rights in immovable property should set out in its schedule the description of the property, its location and generally the registering office within whose jurisdiction the property is situate. Therefore, what is required under item No. 17 of Form 34A is also a necessary recital which is found in any document of conveyance or in any document which purports to transfer, assign, limit or extinguish the right, title or interest of any person to or in any immovable property. Thus items Nos. Therefore, what is required under item No. 17 of Form 34A is also a necessary recital which is found in any document of conveyance or in any document which purports to transfer, assign, limit or extinguish the right, title or interest of any person to or in any immovable property. Thus items Nos. 14 and 17 in Form 34A are concerned with information which are to be found in a completed document referred to as the document in section 230ATherefore, items Nos. 14 and 17 in Form 34A having rightly been introduced by virtue of the undisputed rule-making authority, it appears to me that these items are not in any manner or wise ultra vires of section 230A. In this view of the matter, a writ of certiorari cannot be issued and the rule nisi in W. P. No. 3395 of 1970 is discharged and the writ petition is dismissed. There will be no order as to costs W. P. No. 3394 of 1970 is for the issue of a writ of mandamus directing the Income-tax Officer to issue the necessary certificate as contemplated under section 230A of the Act. In the view I have already taken, there is no statutory obligation or public duty on the part of the first respondent to issue a certificate under section 230A of the Act, if the application for the purpose is not processed through as prescribed under the Act. Here again, the rule nisi is discharged and the writ petition is dismissed. There will be no order as to costs.