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of Set off of refund against oustanding demand u/s 245 - non receipt of notice u/s 245 - stay of demand was granted by the ITAT - It is difficult to appreciate the stand of the respondents that the order passed by the high court would not cover/operate over the matters and orders passed by the ITAT, Union of India being not a party to the matter. Such a justification from and the approach of, the respondent authorities is difficult to be approved of which is not in fitness of stature, especially of the state department, which is supposed to act like a model litigant. - HC
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