In Episode 174 of the anime, Duplica the impressionist and her unusual Ditto "Mini Dit" battle against Team Rocket - her Ditto takes on the appearance of a tiny Wobbuffet. During the battle, Mini Dit uses Mirror Coat after a special attack was used against it. Jessie's confusion leads her to explain that Wobbuffet learn two different moves to return damage - Counter for physical attacks and Mirror Coat for special attacks. All this time, Jessie routinely commanded Counter regardless of the attack, and she comes to the conclusion that her Wobbuffet simply followed its own instinct. Overcome by panic, Jessie and Wobbuffet fail to counter oncoming attacks, leading to a signature blast-off.
The one quarrel I have here is that Wobbuffet should take the initial damage from the attack before being able to return it with twice the power, yet Counter and Mirror Coat seem to deflect all damage. And Ash never thought of attacking indirectly, which is a shame considering this Wobbuffet doesn't seem to know Safeguard or Destiny Bond. Gotta love that anime logic.