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    <title>2026 (4) TMI 1321 - ORISSA HIGH COURT</title>
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    <description>A refund arising from a later assessment year under section 143(1) could not be adjusted against an outstanding demand for an earlier year when recovery of that demand had been stayed under section 220(6) of the Income-tax Act, 1961. The subsisting stay protected the disputed demand during the pendency of the appeal, and appropriation of the refund against that stayed liability was treated as illegal and arbitrary. The refund was therefore directed to be released together with statutory interest under section 244A.</description>
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      <description>A refund arising from a later assessment year under section 143(1) could not be adjusted against an outstanding demand for an earlier year when recovery of that demand had been stayed under section 220(6) of the Income-tax Act, 1961. The subsisting stay protected the disputed demand during the pendency of the appeal, and appropriation of the refund against that stayed liability was treated as illegal and arbitrary. The refund was therefore directed to be released together with statutory interest under section 244A.</description>
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