https://www.taxtmi.com/caselaws?id=462416 Where an administrative recovery instruction limited collection during pendency of appeal to a specified portion of the demand, the Revenue could not retain the entire refund by setting it off against the outstanding tax liability. The court held that adjustment beyond the permissible recovery limit was unjustified, so the excess set-off had to be returned to the assessee. The remaining demand was to stay in abeyance until the appeal was decided, preserving the balance between recovery and appellate protection. en-us Thu, 08 May 2014 00:00:00 +0530 Fri, 20 Jun 2025 21:07:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462416 Where an administrative recovery instruction limited collection during pendency of appeal to a specified portion of the demand, the Revenue could not retain the entire refund by setting it off against the outstanding tax liability. The court held that adjustment beyond the permissible recovery limit was unjustified, so the excess set-off had to be returned to the assessee. The remaining demand was to stay in abeyance until the appeal was decided, preserving the balance between recovery and appellate protection. Case-Laws Income Tax Thu, 08 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462416