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    <title>2024 (12) TMI 1547 - DELHI HIGH COURT</title>
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    <description>Refund adjustment under section 245 was treated as impermissible where the underlying tax demand had been stayed by the ITAT, because recovery protection attached to the stay order could not be bypassed through set-off of the refund. The adjustment was also held invalid because the assessee was not given prior intimation before the refund was appropriated. The refund was therefore restored with applicable interest, and the matter was decided in favour of the assessee.</description>
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      <description>Refund adjustment under section 245 was treated as impermissible where the underlying tax demand had been stayed by the ITAT, because recovery protection attached to the stay order could not be bypassed through set-off of the refund. The adjustment was also held invalid because the assessee was not given prior intimation before the refund was appropriated. The refund was therefore restored with applicable interest, and the matter was decided in favour of the assessee.</description>
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